Transaction Monitoring
TM-05Complete each full investigation within ten business days
How Leela would run itEvent-driven · each case, within 10 business days of opening; 20 with a documented extension
From the policy libraryThe requirement
A case opened at initial review is investigated to a documented conclusion within ten business days, or twenty for a complex case with the AML Compliance Officer’s documented extension. The investigator pulls at least 90 days of transaction history, reviews prior alerts and cases on the customer and related accounts, compares actual activity to the onboarding profile, refreshes watchlist screening on the customer, its owners, and new counterparties, checks open sources, and makes only a limited, non-leading inquiry to the customer that does not reveal an investigation.
- 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
Assemble the history, prior cases, profile comparison, screening results, and open-source review into the case file, record any customer inquiry and answer, and write the conclusion before the clock runs.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Investigation case fileEach step, its result, the customer inquiry if any, and the conclusion
- 02Extension recordOfficer’s reason and new due date for any case past 10 business days
Evidence
Investigation case file
Transaction Monitoring §5.3, §6
2
of 2 records
The work and the records come from this obligation in the policy library.