Sanctions / OFAC
SO-06Clear false positives within 24 hours and escalate unresolved matches
How Leela would run itEvent-driven · each false-positive outcome, within 24 hours; each unresolved match, within four business hours and one business day
From the policy libraryThe requirement
A false positive is documented within 24 hours, naming the fields that distinguish the party from the list entry with evidence attached, and the hold is released only after the write-up is complete. Any suppression is specific to that customer and that list entry, logged with its justification, and reviewed quarterly. A match that cannot be determined stays on hold, is escalated to the AML Compliance Officer within four business hours, and goes to the sponsor bank for guidance within one business day; it is never released for business convenience.
- 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
Write up the distinguishing fields with evidence before releasing a false positive, log any suppression, and for an unresolved match keep the hold, escalate on the clock, and send the bank the partial workpaper.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01False-positive workpaperDistinguishing fields, evidence, determination, time completed, release time
- 02Escalation recordTime escalated to the Officer, time guidance sought from the bank, outcome
- 03Suppression log entryCustomer, list entry, justification, reviewer
Evidence
False-positive workpaper
Sanctions / OFAC §4.3
3
of 3 records
The work and the records come from this obligation in the policy library.