Model policy · version 1

Transaction Monitoring

Watch every transaction on your rails against a documented rule library, work each alert to a written resolution on a clock, and send the sponsor bank a complete referral package when activity cannot be explained. The bank decides whether to file; your job is to make sure nothing reaches it late, thin, or not at all.

What’s in this policy12 sections · Transaction Monitoring · Read the full policy
10Obligations · things you must do
20Evidence · records that prove it
4Monitoring · checks and deadlines
0Reporting · reports you must send

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Answer a few questions and each obligation is marked applies, likely, or needs more information.

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Hand over the whole policy

Every obligation in this policy, in one request.

What the policy requires

Run the workflow

Leela can run the defined steps through your connected systems, with your approvals at the required points.

Monitor

Leela can track records, deadlines and exceptions using your approved rules.

Prepare for review

Leela can prepare the work and supporting evidence for your review and decision.

Specialist-led

A qualified person leads the work and makes the decision; Leela can support the process.

Policy reference§3.1, §3.2, §4.3
Work and review
Run the workflow
TriggerDaily · Each business day, on the day’s on-chain alerts and the bank’s fiat report
EvidenceMonitoring log entry, Alert records
Policy reference§3.3
Work and review
Monitor
TriggerContinuous · Each new customer for 90 days after activation; Tier 2 and 3 customers on their schedule; on any profile change or concern
EvidenceManual review record, New-customer watch list
Policy reference§4.1, §8.2
Work and review
Specialist-led
TriggerEvent-driven · Each proposed rule or threshold change, before it takes effect
EvidenceRule library, Rule change record
Policy reference§5.1, §5.2, §5.3
Work and review
Monitor
TriggerEvent-driven · Each alert: assigned within 1 business day, initial review within 2 business days of assignment
EvidenceAlert record, Closure justification, Alert aging report
Policy reference§5.3, §6
Work and review
Prepare for review
TriggerEvent-driven · Each case, within 10 business days of opening; 20 with a documented extension
EvidenceInvestigation case file, Extension record
Policy reference§7.1
Work and review
Specialist-led
TriggerEvent-driven · Each investigation that concludes with a referral recommendation, before transmission
EvidenceReferral decision record
Policy reference§5.3, §7.2, §7.3
Work and review
Prepare for review
TriggerEvent-driven · Each referral: sent within 2 business days of conclusion; bank follow-ups answered within 2 business days; chased at 30 days without response
EvidenceReferral package, Referral tracker
Policy reference§7.4, §7.5
Work and review
Specialist-led
TriggerContinuous · Always; and for each open referral until the bank’s determination
EvidenceConfidentiality training record, Access log for referral records
Policy reference§8.1, §10
Work and review
Prepare for review
TriggerMonthly · Monthly operating report; calibration review at 90 days after launch and annually
EvidenceMonthly operating report, Calibration memo
Policy reference§9
Work and review
Monitor
TriggerContinuous · Five years from each record’s creation, or the bank’s determination for a referral
EvidenceRetention schedule entry, Production test