Transaction Monitoring
TM-03Control rule changes and notify the bank of material ones
How Leela would run itEvent-driven · each proposed rule or threshold change, before it takes effect
From the policy libraryThe requirement
Every rule in the library carries an identifier, its logic and threshold, the typology it targets, and the rationale for its threshold. Threshold and rule changes follow the Change Management Policy. A material change, meaning a new rule family, a disabled rule, a threshold raised by more than half, or any change to the sanctioned-address blocking logic, requires the AML Compliance Officer’s written approval and advance notice to the sponsor bank’s compliance team.
- 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
Record the proposed change and its rationale, classify it as material or not, obtain the Officer’s written approval where required, send the bank its advance notice, and update the library’s change history.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Rule libraryCurrent version with identifier, logic, threshold, typology, and rationale per rule
- 02Rule change recordChange, materiality, rationale, approver, date, and bank notice sent
Evidence
Rule library
Transaction Monitoring §4.1, §8.2
2
of 2 records
The work and the records come from this obligation in the policy library.