Transaction Monitoring
TM-02Apply heightened manual review to new and elevated-risk customers
How Leela would run itContinuous · each new customer for 90 days after activation; Tier 2 and 3 customers on their schedule; on any profile change or concern
From the policy libraryThe requirement
Beyond the rules, the AML Compliance Officer reviews customer account activity by hand for the indicators rules cannot capture: every new customer in its first 90 days after activation, Tier 2 and Tier 3 customers on their enhanced monitoring schedules, customers whose activity has changed materially from the onboarding profile, and any customer that is the subject of an internal or external concern.
- 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
List the customers in scope each period, review each one’s activity against its expected profile, record the review, and open an alert for anything unusual.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Manual review recordPer customer: reason in scope, period reviewed, reviewer, findings
- 02New-customer watch listActivation date and 90-day end date for each new customer
Evidence
Manual review record
Transaction Monitoring §3.3
2
of 2 records
The work and the records come from this obligation in the policy library.