Sanctions / OFAC
SO-08Review the sanctions program with the bank and train staff each year
How Leela would run itAnnual · each year with the compliance program review; operating report each quarter
From the policy libraryThe requirement
The AML Compliance Officer reviews the sponsor bank’s sanctions policy at least annually and updates this policy to conform, reviews the sanctions program with the sponsor bank’s compliance team at least annually within the compliance program review, and delivers sanctions training to all relevant employees at least annually. Each quarter the Company sends the sponsor bank a sanctions operating report covering volumes, matches by outcome, time to determination, suppression review, re-screening runs, and confirmed events.
- 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
Compare this policy to the bank’s current sanctions policy, hold the joint annual review, deliver and record the training, and send the quarterly operating report.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Annual review recordDate, bank policy version compared, changes made, bank attendees
- 02Training completion rosterEmployee, date, content version
- 03Quarterly sanctions operating reportSent to the sponsor bank with the figures listed in the policy
Evidence
Annual review record
Sanctions / OFAC §5.2, §5.3
3
of 3 records
The work and the records come from this obligation in the policy library.