Leela
Sanctions / OFAC
SO-01

Screen each customer and its owners before activating the account

Policy reference

Sanctions / OFAC policy, §3.1

FFIEC BSA/AML Examination Manual, Office of Foreign Assets Control, FFIEC BSA/AML Examination Manual, OFAC section
Requirement

Every customer, each beneficial owner, and each control person is screened against the SDN List and OFAC’s consolidated sanctions list when onboarding information is submitted. No account is activated and no transaction is processed until a screening result is on file, and the screen is repeated at each periodic review.

Trigger

Event-driven

Each new customer, before account activation; again at each periodic review

Action

Run the watchlist screen on the entity, its owners, and its control persons, record the result against the customer, and keep activation blocked until a clear result or a closed investigation is on file.

Evidence
  • Screening result

    Platform report per entity, owner, and control person with match dispositions

  • Activation gate record

    Date of screening result and date of activation, showing the order

Owner

Operations

Leela can
Monitor

Leela can watch for the trigger, keep the clock, and flag what is late.

Leela can watch that a screening result exists for every customer and owner and flag any account activated without one.

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?