AML Program
AP-07Coordinate escalations, sanctions matches, and 314(a) requests with the bank
How Leela would run itEvent-driven · each unresolved alert, each potential match, and each request, within the timeframe the procedure or the bank sets
From the policy libraryThe requirement
Unusual activity that investigation does not resolve is packaged and escalated to the sponsor bank’s BSA team within the timeframes in the Transaction Monitoring and Unusual Activity Escalation Procedures, and the Company answers the bank’s follow-up inquiries; the bank decides whether to file. A potential sanctions match is frozen and reported to the bank immediately; the bank decides on blocking and reporting. A section 314(a) request that reaches the bank is searched against the Company’s records and answered within the bank’s timeframe. The subject of an escalation is never notified.
- 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.
The work
Open a case on each event, run it under the applicable procedure, send the bank what it needs inside the timeframe, and record the bank’s determination.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Escalation and coordination logPer event: type, date received, date sent to the bank, bank determination, closure
- 02Bank correspondencePackage, notice, or search response with the timestamp
Evidence
Escalation and coordination log
AML Program §7.1, §7.2, §7.3
2
of 2 records
The work and the records come from this obligation in the policy library.