Block a confirmed match and notify the sponsor bank within one hour

Sanctions / OFAC policy, §4.3, §4.4

A confirmed OFAC match is blocked or frozen immediately and no further transactions are processed for the affected party. The sponsor bank is notified within one hour of confirmation, fastest channel first with written notice the same business day, and receives the complete workpaper. The sponsor bank makes the blocking determination, files the blocking report with OFAC within ten business days, and files the annual blocked-property report. No customer or counterparty is told until the bank has decided and agreed to disclosure, and the parties confirm in writing who executes each later step.

Event-driven

Each confirmed match, on confirmation

Block or freeze, stop all further processing for the party, send the confirmed-match notice and workpaper to the sponsor bank inside the hour, record the bank’s decision and filing, and hold all outside communication to agreed neutral language.

• Block action record

  Transaction or account, time blocked, who confirmed the match

• Sponsor bank confirmed-match notice

  Time sent, channel, written follow-up, workpaper attached

• Division of steps log

  Written confirmation of which party executes each subsequent step

AML Compliance Officer

Leela can keep the one-hour clock and stage the workpaper for the notice, but the true-match call and the block are a person’s to make.

Tell Leela about your company to see whether this applies.