Trust transaction monitoring and aml for swift messaging

Trust transaction monitoring and aml for swift messaging

• 1.
  FINTECH TALKS LIVE JULYEDITION TRUST, TRANSACTION MONITORING AND AML FOR SWIFT MESSAGING presented by
• 2.
  OPENING REMARKS CRAIG BEDDIS
• 3.
  PRESENTATION KEITH FURST
• 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$8.9BILLION 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
• 6.
  COMPLIANCE DEVELOPERS
• 7.
  THIS GUY
• 8.
  WAKE UP CALL!
• 9.
  THE PANAMA PAPERS 214,488 200+ 11.5m 12 29 ENTITIES INVOLVED DOCUMENTS LEAKED COUNTRIES INVOLVED FORBES LISTED BILLIONAIRES COUNTRY LEADERS Source: International Consortiumof Investigative Journalists
• 10.
  MT 202 UNDER SCRUTINY SWIFT doesn’tprevent its use Improper use prevents screening Misuse is expensive and manual Regulators are increasing scrutiny on misuse
• 11.
  MT 202 MISUSE EXAMPLE
• 12.
  ANNUAL CERTIFICATION Source: http://www.dfs.ny.gov/legal/regulat ions/proposed/rp504t.pdf The Department ofFinancial 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.
• 13.
  CAN BANKS RE-RISK RATHER THAN DE-RISK?
• 14.
  Country Risk Amount Frequency :20:55555555-5555 :23B:CRED :32A:000555USD5443,99 :33B:USD5443,99 :50K: ORIGINATINGCUSTOMER 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 outsideof their jurisdiction Micro-jurisdictional risk Risk rating methodology and visualization
• 16.
  CUSTOMER BANKING OUTSIDE OF THEIR JURISDICTION RUSSIA BANKING THROUGHLATVIA
• 17.
  MICRO JURISDICTIONAL RISK MOLENBEEK BELGIUM
• 18.
  EVENT DRIVEN RISK
• 19.
  EVENT DRIVEN RISK DID YOU SPOTTHE DIFFERNCE?
• 20.
  IN SUMMARY Do you have/knowyour Unicorns? In a real-time world why calibrate annually? Is your AML technology helping you re-risk vs. de-risk?
• 21.
  LET’S EAT