Transaction Monitoring
TM-08Keep referrals confidential and act only with the bank
How Leela would run itContinuous · always; and for each open referral until the bank’s determination
From the policy libraryThe requirement
The existence of a referral, an investigation, or a suspicious activity report is never disclosed to a customer, consumer, or other third party, and the prohibition binds every employee and contractor. Between referral and the sponsor bank’s determination the Company keeps the account operating unless the bank instructs otherwise or a sanctions match or other emergency requires a freeze; it does not close or restrict an account on a pending referral alone without coordinating with the bank.
- 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
Train every employee and contractor on the prohibition, keep referral records on restricted access, and route any proposed account restriction on a referred customer through the bank before acting.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Confidentiality training recordPer employee and contractor, with date
- 02Access log for referral recordsWho viewed each referral and when
Evidence
Confidentiality training record
Transaction Monitoring §7.4, §7.5
2
of 2 records
The work and the records come from this obligation in the policy library.