Model policy · version 1
Sanctions / OFAC
Screen every customer, owner, and transaction against the OFAC lists, hold anything that looks like a match, and get the sponsor bank the facts it needs to block and report within the hour. Sanctions liability is strict, so the clocks in this policy are the control.
What’s in this policy8 sections · Sanctions / OFAC · Read the full policy
9Obligations · things you must do
24Evidence · records that prove it
3Monitoring · 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; again at each periodic review
EvidenceScreening result, Activation gate record
TriggerContinuous · Every digital-asset transaction as it is initiated; alerts the same business day
EvidenceAlert record, Hold and notification log, Configuration sign-off
TriggerEvent-driven · Each wire at or above the threshold, before transmission; weekly flag export until the routing protocol is live
EvidencePre-transmission screening record, Fiat screening protocol, Weekly flag export
TriggerEvent-driven · Each potential match on any screening surface, immediately on the alert
EvidenceHold log, Sponsor bank potential-match notice, Match workpaper
TriggerEvent-driven · Each confirmed match, on confirmation
EvidenceBlock action record, Sponsor bank confirmed-match notice, Division of steps log
TriggerEvent-driven · Each false-positive outcome, within 24 hours; each unresolved match, within four business hours and one business day
EvidenceFalse-positive workpaper, Escalation record, Suppression log entry
TriggerDaily · Daily list check; delta re-screen promptly on each publication
EvidenceDaily monitoring log entry, Delta re-screening run record
TriggerAnnual · Each year with the compliance program review; operating report each quarter
EvidenceAnnual review record, Training completion roster, Quarterly sanctions operating report
TriggerContinuous · Five years from each record; from the transaction date for blocking records
EvidenceRetention schedule entry, Suppression log