Leela
Sanctions / OFAC
SO-03

Pre-screen wire beneficiaries and align fiat screening with the bank

Requirement

Fiat payments are screened by the sponsor bank in its own systems, and the Company documents which screens the bank runs on the program and which alerts it routes back for investigation; until that protocol is live, the AML Compliance Officer requests a weekly export of fiat sanctions flags. Independently, the beneficiary of every wire at or above the program threshold is reviewed against the SDN List before transmission, and cross-border wires are screened for comprehensive-program jurisdiction risk.

Trigger

Event-driven

Each wire at or above the threshold, before transmission; weekly flag export until the routing protocol is live

Action

Screen each qualifying wire beneficiary before release, agree the fiat alert routing with the sponsor bank in writing, and collect the weekly export until routing is in place.

Evidence
  • Pre-transmission screening record

    Per wire: beneficiary, list version, result, time, releaser

  • Fiat screening protocol

    Written agreement with the sponsor bank on screens run and alerts routed

  • Weekly flag export

    Export received, date, flags and dispositions

Owner

Operations

Leela can
Monitor

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

Leela can hold each qualifying wire until its screening result is recorded and chase the weekly export while the protocol is pending.

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?