Sanctions / OFAC
SO-03Pre-screen wire beneficiaries and align fiat screening with the bank
How Leela would run itEvent-driven · each wire at or above the threshold, before transmission; weekly flag export until the routing protocol is live
From the policy libraryThe requirement
Fiat payments are screened by the sponsor bank in its own systems, and the Company documents which screens the bank runs on the program and which alerts it routes back for investigation; until that protocol is live, the AML Compliance Officer requests a weekly export of fiat sanctions flags. Independently, the beneficiary of every wire at or above the program threshold is reviewed against the SDN List before transmission, and cross-border wires are screened for comprehensive-program jurisdiction risk.
- 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
Screen each qualifying wire beneficiary before release, agree the fiat alert routing with the sponsor bank in writing, and collect the weekly export until routing is in place.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Pre-transmission screening recordPer wire: beneficiary, list version, result, time, releaser
- 02Fiat screening protocolWritten agreement with the sponsor bank on screens run and alerts routed
- 03Weekly flag exportExport received, date, flags and dispositions
Evidence
Pre-transmission screening record
Sanctions / OFAC §3.3
3
of 3 records
The work and the records come from this obligation in the policy library.