Keep referrals confidential and act only with the bank

Transaction Monitoring policy, §7.4, §7.5

The existence of a referral, an investigation, or a suspicious activity report is never disclosed to a customer, consumer, or other third party, and the prohibition binds every employee and contractor. Between referral and the sponsor bank’s determination the Company keeps the account operating unless the bank instructs otherwise or a sanctions match or other emergency requires a freeze; it does not close or restrict an account on a pending referral alone without coordinating with the bank.

Continuous

Always; and for each open referral until the bank’s determination

Train every employee and contractor on the prohibition, keep referral records on restricted access, and route any proposed account restriction on a referred customer through the bank before acting.

• Confidentiality training record

  Per employee and contractor, with date

• Access log for referral records

  Who viewed each referral and when

AML Compliance Officer

Leela can restrict who sees referral records, log access, and flag any account action proposed on a customer with an open referral.

Tell Leela about your company to see whether this applies.