Keep a violation-reporting channel with no retaliation

AML Program policy, §9

Any employee, contractor, or service provider who suspects a violation of this policy or of AML law reports it to the AML Compliance Officer immediately, verbally or in writing, and no one who reports in good faith is retaliated against. Violations may lead to discipline up to termination, and where potential criminal conduct is involved the officer coordinates the response with the sponsor bank and outside counsel.

Continuous

Channel open at all times; each report acted on when received

Publish the channel to staff, log each report, investigate it, decide the response with the bank and counsel where criminal conduct is possible, and record the outcome.

• Violation report log

  Per report: date, summary, investigation, outcome

• Staff acknowledgment

  Record that each person received the policy and the reporting channel

AML Compliance Officer

Leela can log each report as a case and keep it open until the officer records an outcome.

Tell Leela about your company to see whether this applies.