AML Program
AP-08Keep a violation-reporting channel with no retaliation
How Leela would run itContinuous · channel open at all times; each report acted on when received
From the policy libraryThe requirement
Any employee, contractor, or service provider who suspects a violation of this policy or of AML law reports it to the AML Compliance Officer immediately, verbally or in writing, and no one who reports in good faith is retaliated against. Violations may lead to discipline up to termination, and where potential criminal conduct is involved the officer coordinates the response with the sponsor bank and outside counsel.
- 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
Publish the channel to staff, log each report, investigate it, decide the response with the bank and counsel where criminal conduct is possible, and record the outcome.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Violation report logPer report: date, summary, investigation, outcome
- 02Staff acknowledgmentRecord that each person received the policy and the reporting channel
Evidence
Violation report log
AML Program §9
2
of 2 records
The work and the records come from this obligation in the policy library.