Hold activity and open a match investigation within one business hour

Sanctions / OFAC policy, §4.1, §4.2

On any potential match, all activity on the affected account or transaction is held and the hold time logged, the AML Compliance Officer or a designee opens an investigation within one business hour, and the sponsor bank’s compliance team is notified within one business hour. The investigator compares the hit to the list entry field by field, gathers documentation, registry, public-record, and attribution evidence, applies the 50 percent rule to unlisted parties, notes any general license, and records a determination in the workpaper.

Event-driven

Each potential match on any screening surface, immediately on the alert

Place the hold, log its time, open the investigation, send the sponsor bank the potential-match notice, and work the comparison, enrichment, ownership, and license steps into the workpaper.

• Hold log

  Account or transaction, hold time, who placed it

• Sponsor bank potential-match notice

  Sent within one business hour, with the time and channel

• Match workpaper

  Fields compared, evidence gathered, ownership analysis, determination

AML Compliance Officer

Leela can log the hold, keep the one-business-hour clocks for the investigation and the bank notice, and assemble the comparison fields into the workpaper.

Tell Leela about your company to see whether this applies.