Transaction Monitoring
TM-10

Retain alerts, cases, referrals, and calibration records five years

Policy reference

Transaction Monitoring policy, §9

Bank Secrecy Act regulations, reports by banks of suspicious transactions, retention of records, 31 CFR 1020.320(d)
Requirement

Every alert with its resolution, every investigation case file, every referral package, the sponsor bank’s response or filing confirmation for each referral, the monitoring log, and every calibration memo and rule change approval are retained for at least five years, in a form the Company can produce for sponsor bank testing and regulatory examination.

Trigger

Continuous

Five years from each record’s creation, or the bank’s determination for a referral

Action

File each record class under the retention schedule, key each retention date to the record, and be able to produce any alert, case, or referral on request.

Evidence
  • Retention schedule entry

    Record class, retention period, storage location, retrieval owner

  • Production test

    A sample alert, case, and referral retrieved on request, with the time taken

Owner

AML Compliance Officer

Work and review
Monitor

Leela can track records, deadlines and exceptions using your approved rules.

Leela can hold each record with its retention date, block early disposal, and produce any file on request.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?