Leela
Issues Management
IM-02

Classify each issue by severity on the four-level scale

Policy reference

Issues Management policy, §4, §11

CFPB Supervision and Examination Manual, Compliance Management Review, CMR, Compliance Program: monitoring and corrective action
FFIEC BSA/AML Examination Manual, Assessing the BSA/AML Compliance Program, independent testing
Requirement

Each registered issue is rated Critical, High, Moderate, or Low against the definitions in the severity table. The rating sets the escalation path, the investigation clock, and the remediation window. An AML issue escalated under the AML quality assurance framework is rated at least High.

Trigger

Event-driven

Each issue, at registration; re-rated if the investigation changes the picture

Action

Compare the issue to the severity definitions and examples, record the rating and the reason in the log, and apply the AML severity floor where it applies.

Evidence
  • Severity rating

    Rating, rationale, rater, and date on the Issues Log entry

Owner

Compliance Officer

Leela can
Human required

A person must do the work; Leela can track it and file the evidence.

Leela can lay the issue against the severity table and suggest a rating, but the Compliance Officer decides it.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?