Control rule changes and notify the bank of material ones

Transaction Monitoring policy, §4.1, §8.2

Every rule in the library carries an identifier, its logic and threshold, the typology it targets, and the rationale for its threshold. Threshold and rule changes follow the Change Management Policy. A material change, meaning a new rule family, a disabled rule, a threshold raised by more than half, or any change to the sanctioned-address blocking logic, requires the AML Compliance Officer’s written approval and advance notice to the sponsor bank’s compliance team.

Event-driven

Each proposed rule or threshold change, before it takes effect

Record the proposed change and its rationale, classify it as material or not, obtain the Officer’s written approval where required, send the bank its advance notice, and update the library’s change history.

• Rule library

  Current version with identifier, logic, threshold, typology, and rationale per rule

• Rule change record

  Change, materiality, rationale, approver, date, and bank notice sent

AML Compliance Officer

Leela can hold the library, flag which proposed changes meet the materiality test, and file the approval and bank notice against each change.

Tell Leela about your company to see whether this applies.