Sign off every referral before it goes to the sponsor bank

Transaction Monitoring policy, §7.1

Where an investigation concludes that the activity cannot be explained by a legitimate business purpose, or that the explanation does not fully account for the pattern, the investigator prepares a referral recommendation. The AML Compliance Officer reviews every recommendation and every package before transmission; no referral package is sent without the Officer’s sign-off, and a decision not to refer is documented as carefully as a decision to refer.

Event-driven

Each investigation that concludes with a referral recommendation, before transmission

Review the case file and the draft package, decide whether the activity is referred, record the decision and its reasons, and release the package only on sign-off.

• Referral decision record

  Recommendation, Officer’s decision and reasons, signature and date

AML Compliance Officer

Leela can route each recommendation to the Officer with the case file attached, hold the package until the sign-off is recorded, and file the decision.

Tell Leela about your company to see whether this applies.