Trust transaction monitoring and aml for swift messaging
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Transcript of Trust transaction monitoring and aml for swift messaging
FINTECH TALKS LIVEJULY EDITION
TRUST, TRANSACTION MONITORING AND AML FOR SWIFT MESSAGING
presented by
OPENING REMARKS
CRAIG BEDDIS
PRESENTATION
KEITH FURST
OFACFINES
Source: https://risk.thomsonreuters.com/en/resources/infographic/fines-banks-breached-us-sanctions.html
2012 $1.9 BILLION
2013 $100 MILLION
2014 $8.9 BILLION
2015 $1.45 BILLION
MODELRISK MANAGEMENT
Source: http://www.occ.treas.gov/news-issuances/bulletins/2011/bulletin-2011-12a.pdf
Governance
Model Validation
Model Development, Implementation & Use
COMPLIANCE
DEVELOPERS
THIS GUY
WAKE UP CALL!
THEPANAMAPAPERS
214,488
200+11.5m
1229
ENTITIESINVOLVED
DOCUMENTSLEAKED
COUNTRIESINVOLVED
FORBES LISTEDBILLIONAIRES
COUNTRYLEADERSSource: International
Consortium of Investigative Journalists
MT 202UNDERSCRUTINY
SWIFT doesn’t prevent its use
Improper use prevents screening
Misuse is expensive and manual
Regulators are increasing scrutiny on misuse
MT 202MISUSEEXAMPLE
ANNUALCERTIFICATION
Source: http://www.dfs.ny.gov/legal/regulations/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.
CAN BANKSRE-RISK RATHER THAN DE-RISK?
Country Risk
Amount
:20:55555555-5555:23B:CRED:32A:000555USD5443,99:33B:USD5443,99:50K: ORIGINATING CUSTOMERNAPLES IT:52A:BCITITMM500:53A:BCITUS33:54A:IRVTUS3N:57D: BNP PARIBAS S.A.GRENOBLE FRANCE:59F:/555555555555555555551/BENEFICIARY CUSTOMER2/ADDRESS LINE 13/BE/BRUSSELS:70:/RFB/INVOICE 5555555:71A:SHA:72:/ABCD/narrative//more narrative/EFGH/narrative
BLOCK 3
RE-RISKINGCRITERIA
Customer banking outside of their jurisdiction
Micro-jurisdictional risk
Risk rating methodology and visualization
CUSTOMERBANKINGOUTSIDEOF THEIRJURISDICTION
RUSSIA BANKINGTHROUGH LATVIA
MICROJURISDICTIONALRISK
MOLENBEEKBELGIUM
EVENTDRIVENRISK
EVENTDRIVENRISK
DID YOU SPOT THEDIFFERNCE?
INSUMMARY
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?
LET’S EAT