Model policy · version 1
KYC / CIP / KYB
Know exactly who you onboard, who owns them, and how much diligence each one needs, then keep that picture current. This is the gate that keeps shell companies and sanctioned parties off the platform, and the file an examiner opens first.
What’s in this policy11 sections · KYC / CIP / KYB · Read the full policy
10Obligations · things you must do
17Evidence · records that prove it
2Monitoring · checks and deadlines
0Reporting · reports you must send
Does this apply to you?
Answer a few questions and each obligation is marked applies, likely, or needs more information.
Tell Leela about your companyHand over the whole policy
Every obligation in this policy, in one request.
What the policy requires
Automate
Leela can perform the work through your connected systems.
Monitor
Leela can watch for the trigger, keep the clock, and flag what is late.
Prepare for review
Leela can prepare the artifact and hand it to a person for review.
Human required
A person must do the work; Leela can track it and file the evidence.
TriggerEvent-driven · Each new customer, before account activation
EvidenceOnboarding record, Formation and license documents
TriggerEvent-driven · Each new customer, before account activation
EvidenceScreening result
TriggerEvent-driven · Each legal-entity customer, before account activation
EvidenceBeneficial ownership certification, Owner verification and screening results
TriggerEvent-driven · At onboarding, and at each periodic review
EvidenceTier assignment record, Enhanced due diligence package
TriggerEvent-driven · Each Tier 3 customer, before activation; each new business type, before the first one
EvidenceRisk memo, Sponsor bank pre-approval
TriggerEvent-driven · At onboarding through the customer agreement, and at each periodic review for Tier 2 and 3
EvidenceExecuted customer agreement, Consumer program evidence
TriggerAnnual · Annual, six-monthly, or quarterly per customer by tier
EvidencePeriodic review record
TriggerContinuous · On every watchlist update; promptly on any trigger event
EvidenceRe-screening log, Out-of-cycle review record
TriggerEvent-driven · On each material change; on each offboarding trigger
EvidenceChange refresh record, Offboarding decision
TriggerContinuous · Five years from each customer’s offboarding
EvidenceRetention schedule entry