Sanctions / OFAC
SO-04Hold activity and open a match investigation within one business hour
How Leela would run itEvent-driven · each potential match on any screening surface, immediately on the alert
From the policy libraryThe requirement
On any potential match, all activity on the affected account or transaction is held and the hold time logged, the AML Compliance Officer or a designee opens an investigation within one business hour, and the sponsor bank’s compliance team is notified within one business hour. The investigator compares the hit to the list entry field by field, gathers documentation, registry, public-record, and attribution evidence, applies the 50 percent rule to unlisted parties, notes any general license, and records a determination in the workpaper.
- 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
Place the hold, log its time, open the investigation, send the sponsor bank the potential-match notice, and work the comparison, enrichment, ownership, and license steps into the workpaper.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Hold logAccount or transaction, hold time, who placed it
- 02Sponsor bank potential-match noticeSent within one business hour, with the time and channel
- 03Match workpaperFields compared, evidence gathered, ownership analysis, determination
Evidence
Hold log
Sanctions / OFAC §4.1, §4.2
3
of 3 records
The work and the records come from this obligation in the policy library.