Trust transaction monitoring and aml for swift messaging
- 1. FINTECH TALKS LIVE JULY EDITION TRUST, TRANSACTION MONITORING AND AML FOR SWIFT MESSAGING presented by
- 4. OFAC FINES Source: https://risk.thomsonreuters.com/e n/resources/infographic/fines- banks-breached-us- sanctions.html 2012$1.9 BILLION 2013$100 MILLION 2014$8.9 BILLION 2015$1.45 BILLION
- 5. MODEL RISK MANAGEMENT Source: http://www.occ.treas.gov/news- issuances/bulletins/2011/bulletin- 2011-12a.pdf Governance Model Validation Model Development, Implementation & Use
- 7. THIS GUY
- 9. THE PANAMA PAPERS 214,488 200+ 11.5m 12 29 ENTITIES INVOLVED DOCUMENTS LEAKED COUNTRIES INVOLVED FORBES LISTED BILLIONAIRES COUNTRY LEADERS Source: International Consortium of Investigative Journalists
- 10. MT 202 UNDER SCRUTINY SWIFT doesn’t prevent its use Improper use prevents screening Misuse is expensive and manual Regulators are increasing scrutiny on misuse
- 12. ANNUAL CERTIFICATION Source: http://www.dfs.ny.gov/legal/regulat ions/proposed/rp504t.pdf The Department of Financial Services (the “Department”) has recently been involved in a number of investigations into compliance by Regulated Institutions, as defined below, with applicable Bank Secrecy Act/Anti-Money Laundering laws and regulations1 (“BSA/AML”) and Office of Foreign Assets Control (“OFAC”)2 requirements implementing federal economic and trade sanctions. As a result of these investigations, the Department has become aware of the shortcomings in the transaction monitoring and filtering programs of these institutions and that a lack of robust governance, oversight, and accountability at senior levels of these institutions has contributed to these shortcomings. The Department believes that other financial institutions may also have shortcomings in their transaction monitoring programs for monitoring transactions for suspicious activities, and watch list filtering programs, for “real-time” interdiction or stopping of transactions on the basis of watch lists, including OFAC or other sanctions lists, politically exposed persons lists, and internal watch lists.
- 14. Country Risk Amount Frequency :20:55555555-5555 :23B:CRED :32A:000555USD5443,99 :33B:USD5443,99 :50K: ORIGINATING CUSTOMER NAPLES IT :52A:BCITITMM500 :53A:BCITUS33 :54A:IRVTUS3N :57D: BNP PARIBAS S.A. GRENOBLE FRANCE :59F:/55555555555555555555 1/BENEFICIARY CUSTOMER 2/ADDRESS LINE 1 3/BE/BRUSSELS :70:/RFB/INVOICE 5555555 :71A:SHA :72:/ABCD/narrative //more narrative /EFGH/narrative BLOCK3
- 15. RE-RISKING CRITERIA Customer banking outside of their jurisdiction Micro-jurisdictional risk Risk rating methodology and visualization
- 19. EVENT DRIVEN RISK DID YOU SPOT THE DIFFERNCE?
- 20. IN SUMMARY Do you have/know your Unicorns? In a real-time world why calibrate annually? Is your AML technology helping you re-risk vs. de-risk?
- 21. LET’S EAT