Send the referral package in two business days and track it

Transaction Monitoring policy, §5.3, §7.2, §7.3

A signed-off referral package is transmitted to the sponsor bank’s BSA team through the agreed secure channel within two business days of the investigation’s conclusion. It contains the narrative, the parties, the transaction records, prior alerts and referrals, screening results, any customer explanation, and an urgency recommendation. The Company tracks every open referral, answers any bank follow-up within two business days, and follows up with the bank on any referral with no response after 30 days.

Event-driven

Each referral: sent within 2 business days of conclusion; bank follow-ups answered within 2 business days; chased at 30 days without response

Assemble the package from the case file, transmit it on the agreed channel, record the bank’s acknowledgment, answer follow-ups on the clock, and chase any referral silent for 30 days.

• Referral package

  Complete package as transmitted, with the transmission record

• Referral tracker

  Per referral: sent, acknowledged, follow-ups, 30-day chase, bank determination

AML Compliance Officer

Leela can assemble the referral package from the case file, keep the two-day and 30-day clocks on each referral, and draft the follow-up when one falls due.

Tell Leela about your company to see whether this applies.