Clear false positives within 24 hours and escalate unresolved matches

Sanctions / OFAC policy, §4.3

A false positive is documented within 24 hours, naming the fields that distinguish the party from the list entry with evidence attached, and the hold is released only after the write-up is complete. Any suppression is specific to that customer and that list entry, logged with its justification, and reviewed quarterly. A match that cannot be determined stays on hold, is escalated to the AML Compliance Officer within four business hours, and goes to the sponsor bank for guidance within one business day; it is never released for business convenience.

Event-driven

Each false-positive outcome, within 24 hours; each unresolved match, within four business hours and one business day

Write up the distinguishing fields with evidence before releasing a false positive, log any suppression, and for an unresolved match keep the hold, escalate on the clock, and send the bank the partial workpaper.

• False-positive workpaper

  Distinguishing fields, evidence, determination, time completed, release time

• Escalation record

  Time escalated to the Officer, time guidance sought from the bank, outcome

• Suppression log entry

  Customer, list entry, justification, reviewer

AML Compliance Officer

Leela can draft the false-positive write-up from the comparison fields and keep the 24-hour, four-hour, and one-day clocks for a person to close.

Tell Leela about your company to see whether this applies.