Complete each full investigation within ten business days

Transaction Monitoring policy, §5.3, §6

A case opened at initial review is investigated to a documented conclusion within ten business days, or twenty for a complex case with the AML Compliance Officer’s documented extension. The investigator pulls at least 90 days of transaction history, reviews prior alerts and cases on the customer and related accounts, compares actual activity to the onboarding profile, refreshes watchlist screening on the customer, its owners, and new counterparties, checks open sources, and makes only a limited, non-leading inquiry to the customer that does not reveal an investigation.

Event-driven

Each case, within 10 business days of opening; 20 with a documented extension

Assemble the history, prior cases, profile comparison, screening results, and open-source review into the case file, record any customer inquiry and answer, and write the conclusion before the clock runs.

• Investigation case file

  Each step, its result, the customer inquiry if any, and the conclusion

• Extension record

  Officer’s reason and new due date for any case past 10 business days

AML Compliance Officer

Leela can assemble the transaction history, prior cases, profile comparison, and screening results into a draft case file for the investigator to work and conclude.

Tell Leela about your company to see whether this applies.