Transaction Monitoring
TM-06Sign off every referral before it goes to the sponsor bank
How Leela would run itEvent-driven · each investigation that concludes with a referral recommendation, before transmission
From the policy libraryThe requirement
Where an investigation concludes that the activity cannot be explained by a legitimate business purpose, or that the explanation does not fully account for the pattern, the investigator prepares a referral recommendation. The AML Compliance Officer reviews every recommendation and every package before transmission; no referral package is sent without the Officer’s sign-off, and a decision not to refer is documented as carefully as a decision to refer.
- 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
Review the case file and the draft package, decide whether the activity is referred, record the decision and its reasons, and release the package only on sign-off.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Referral decision recordRecommendation, Officer’s decision and reasons, signature and date
Evidence
Referral decision record
Transaction Monitoring §7.1
1
of 1 record
The work and the records come from this obligation in the policy library.