Coordinate escalations, sanctions matches, and 314(a) requests with the bank

AML Program policy, §7.1, §7.2, §7.3

Unusual activity that investigation does not resolve is packaged and escalated to the sponsor bank’s BSA team within the timeframes in the Transaction Monitoring and Unusual Activity Escalation Procedures, and the Company answers the bank’s follow-up inquiries; the bank decides whether to file. A potential sanctions match is frozen and reported to the bank immediately; the bank decides on blocking and reporting. A section 314(a) request that reaches the bank is searched against the Company’s records and answered within the bank’s timeframe. The subject of an escalation is never notified.

Event-driven

Each unresolved alert, each potential match, and each request, within the timeframe the procedure or the bank sets

Open a case on each event, run it under the applicable procedure, send the bank what it needs inside the timeframe, and record the bank’s determination.

• Escalation and coordination log

  Per event: type, date received, date sent to the bank, bank determination, closure

• Bank correspondence

  Package, notice, or search response with the timestamp

AML Compliance Officer

Leela can keep the bank’s clock on each escalation, match, and request and flag what is about to run late.

Tell Leela about your company to see whether this applies.