Review the sanctions program with the bank and train staff each year
Sanctions / OFAC policy, §5.2, §5.3
The AML Compliance Officer reviews the sponsor bank’s sanctions policy at least annually and updates this policy to conform, reviews the sanctions program with the sponsor bank’s compliance team at least annually within the compliance program review, and delivers sanctions training to all relevant employees at least annually. Each quarter the Company sends the sponsor bank a sanctions operating report covering volumes, matches by outcome, time to determination, suppression review, re-screening runs, and confirmed events.
Annual
Each year with the compliance program review; operating report each quarter
Compare this policy to the bank’s current sanctions policy, hold the joint annual review, deliver and record the training, and send the quarterly operating report.
- Annual review record
Date, bank policy version compared, changes made, bank attendees
- Training completion roster
Employee, date, content version
- Quarterly sanctions operating report
Sent to the sponsor bank with the figures listed in the policy
AML Compliance Officer
A person must do the work; Leela can track it and file the evidence.
Leela can keep the annual and quarterly dates, assemble the operating report figures, and track who has completed training.
Tell Leela about your company to see whether this applies.
Tell Leela how you handle it today, or hand it over: see what’s next.