渣打银行制裁合规管理框架幻灯片课件

1、2 July 2010,Victor Matafonov, Group Head of Systems and Monitoring, Financial Crime Risk Martin RowlandsGroup Sanctions Adviser,Introduction sanctions compliance roles,Victor Matafonov Group Head of Systems and Monitoring, Financial Crime Risk Sets standards for operation of Groups screening systems

2、 Oversees deployment of screening lists Ensure systems users have proper guidance Assurance Martin Rowlands - Group Sanctions Advisor Maintains Group Policy and Procedures Training General advice and internal reporting Transactional advice Regulatory relationships,2,Agenda,Introduction Nature and im

3、pact of sanctions Sanctions compliance in banks Compliance challenges System selection process,3,Introduction to Standard Chartered Bank (SCB),4,Established for over 150 years Dual-primary listed - London, HK Top 15 of FTSE 100 companies Regulated by FSA 73,800 employees, 125 nationalities 75 countr

4、ies and territories Income $15.2 b, PBT $5.1b, Assets $435b American Express Bank acquired Feb 08,Key facts,Focus on Asia, Africa and the Middle East,*Based on Final Results 2009,Our Business,Consumer Bank,Wholesale Bank,5,International Profile,6,Focus on Asia, Africa and Middle East,International s

5、anctions,Nature and impact of international sanctions,7,International sanctions,Sanctions are measures imposed by governments to deprive a country, organisation or individual of: Financial and/or economic assets The benefit of trade Economic interaction with the country or countries imposing or impl

6、ementing sanctions,8,International sanctions,US sanctions against named parties, and against six countries (Myanmar / Burma, Cuba, Iran, North Korea, Sudan, Syria) UK sanctions against named parties,9,International sanctions,United Nations sanctions European Union sanctions Other country sanctions a

7、gainst named countries or parties, e.g. country boycotts of Israel; country sanctions against named parties,10,Impact of sanctions,Criminal offences corporate entities individuals Regulatory and/or criminal fines Regulatory reviews, audits and enforcement actions Licence issues Reputational impact,1

8、1,Impact of sanctions,Sanctions remain a priority for major regulators: UK: FSA April 2009 - thematic review on UK sanctions: “We expect firms to implement more effective systems and controls.” US: Credit Suisse December 2009 - $536m fine over Iran sanctions; ABN Amro May 2010 additional $500m fine.

9、 Sanctions compliance remains a top priority in SCBs Compliance and Assurance agenda for 2010, which projects further enhancements to the Groups sanctions compliance programme.,12,Our approach to sanctions compliance,Continuous improvement approach Actively seeking opportunities to enhance processes

10、 Ongoing benchmarking Commitment to remain at industry best practice Integral part of the Groups sustainability programme,13,Sanctions compliance,Sanctions compliance in banks,14,Sanctions compliance programme,A comprehensive sanctions compliance programme includes the following elements: I Policies

11、 and procedures II Training and awareness III Automated screening systems IV Management information and Assurance V Governance and oversight,15,Compliance programme objectives,I Policies and Procedures Maintain in line with changing regulation and industry best practice Continuously improve clarity

12、and ease of use II Training and Awareness Raise awareness of sanctions compliance risks Improve the technical understanding of targeted staff,16,Compliance programme objectives,III Automated Screening Systems Ongoing improvement: effectiveness and operational efficiency Align screening capabilities

13、with changing best practice Maximise standardisation across the Group IV Assurance Maintain/ improve framework of controls, management information and assurance V Governance and Oversight Develop and drive sanctions compliance strategy Ensure effective management oversight maintained,17,Sanctions co

14、mpliance programme,I Policies and Procedures,18,19,Policies and Procedures,Policies and Procedures,Policy and Procedures apply globally (subject to dispensations) Clear rules which describe transaction types permitted and prohibited Clear responsibilities for advising Operational procedures focussed

15、 on key risk areas those which make payments or release assets,20,Policies and Procedures,Group Sanctions Policy Country Sanctions Procedures and US Persons Procedure Procedures concerning dealings with named sanctioned parties US sanctioned parties UK sanctioned parties,21,Policies and procedures -

16、 challenges,Clarity and simplicity in procedures Prohibition of attempts to circumvent sanctions Escalation process Internal reporting of any departures from procedures and preventive steps,22,Sanctions compliance programme,II Training and Awareness,23,Training and awareness,Sanctions elements in tr

17、aining for basic banking processes (e.g. account opening) Sanctions components in Financial Crime Risk related training (e.g. Anti Money Laundering eLearning) Periodic sanctions-specific training for target groups: Trade teams Cash Management teams Country Heads of Financial Crime Risk Relationship

18、Management teams,24,Sanctions compliance programme,III Automated screening systems (refer end of presentation),25,Sanctions compliance programme,IV Management Information & Assurance,26,Management Information & Assurance,Metrics and Management Information Monthly account and transaction screening me

19、trics. Country Financial Crime Risk staff track issues to resolution. Consolidated numbers reported to Group Financial Crime Risk Committee. Risk Assessment and Assurance Key Control Self Assessment to ensure compliance with policies and procedures in training and customer / transaction screening. O

20、ngoing risk assessment of products and services. External benchmarking.,27,Sanctions compliance programme,V Governance and oversight,28,Governance and Oversight,Country Financial Crime Risk teams Country management Regional Compliance Head Country operations teams Country management Group Operations

21、 Group Financial Crime Risk Group Head, Compliance and Assurance Group Board,29,Sanctions compliance programme,III Automated screening systems,30,Automated Screening Systems,Agenda Watchlists Overview of screening processes, workflows and guidance: Customer screening Transaction screening Continuous

22、 improvement processes Challenges Risk assessment Initiatives underway Assurance Systems selection process,31,Group Watch lists - Sources,The Groups watch lists are made up of the following components: External vendor provided data consolidated regulatory lists and specialist value added lists Exter

23、nal data not publicly available (e.g. from some regulators such as Singapore) Internal Group watch lists (i.e. prohibited names, country names, SWIFT Bank Identification Codes). Internal country specific watch lists (e.g. lists of credit defaulters, fraudsters, exited accounts etc). By far the bigge

24、st component is from the external vendor (i.e. more than 1 million names). They provide us with names in 3 broad categories: A consolidation of publicly available regulatory lists including UK Her Majestys Treasury (HMT) list, US Office of Office of Foreign Asset Control (OFAC), UN, EU. A listing of

25、 Politically Exposed Persons (PEPs) A listing of names associated with adverse media,32,33,33,Group Watch lists - Uses,Global screening of potential and existing customer names and select other parties (e.g. counterparties in Trade, directors of corporate entities etc) against: All Group watchlists

26、Global screening of transactions (e.g. SWIFT messages) against: Global regulatory lists (i.e. HMT, OFAC, Enhanced OFAC, US Patriot Act). Global internal lists (i.e. prohibited names, country names, BIC codes) Country specific sanctions lists (e.g. MAS, HKMA, UN),34,34,34,Overview of Screening Proces

27、ses,Automated screening of customers and other parties (e.g. counterparties, directors or beneficial owners of corporate entities, staff, vendors etc) against the all Group watch lists: Prior to account opening or undertaking selected transactions (e.g. trade) Periodically to ensure existing custome

28、rs / other parties have not been added to watch lists. Looking for name or word matches Pre and after the event Outcomes of confirmed matches: Reject new account or transaction application. Take appropriate action on existing account in accordance with Group Customer Due Diligence (CDD) / Sanctions

29、policies and procedures. Amend risk rating. Issue Suspicious Activity Report (SAR),Automated screening of transactions (e.g. SWIFT messages) against the following watchlists: Global regulatory lists (i.e. HMT, OFAC, Enhanced OFAC, US Patriot Act). Global internal lists (i.e. prohibited names, countr

30、y names, BIC codes) Country specific mandatory lists (e.g. MAS, HKMA, UN) Looking for name or word matches. Real time prior to message being sent or acted upon. Outcomes of confirmed matches: Reject transaction. Take appropriate action on transaction in accordance with Group Sanctions policies and p

31、rocedures. Amend customer risk rating. Issue SAR.,Screening of customer / other party names,Screening of transactions,35,35,35,Screening Statistics - Group,Customer Due Diligence (CDD) screening at account opening: Approx.16k registered users across the Group undertake approx. 400 k searches every m

32、onth as part of Customer Due Diligence processes and other investigative searches. This results in approx. 52 k alerts (potential matches) per month being investigated across the Group. Periodic customer screening: Periodic rescreen of the entire customer base (approx. 15 m retail and 126 k wholesal

33、e customers) against all Group watch lists. This results in approx. 160 k alerts per month being investigated by approx. 75 staff within the Chennai SSC and in the respective countries. Transaction screening: Up to 7 m payment messages are screened per month for sanctions purposes, generating up to

34、460 k alerts per month for further investigation. The equivalent of approximately 70 full time operations staff are involved in sanctions screening processes.,WLM Watch List Manager WLM feeds two functions:- AOC Account Opening Check for new customers. CMR Customer Match Report for periodic screenin

35、g of existing accounts,WLM,AOC,CMR,16,000 users across the Group access AOC to identify high risk sanctioned and high risk names prior to account opening,External Vendor Lists Regulatory Lists PEPs & Associates Adverse Media Enhanced lists,Internal Lists Group lists Country Lists,Periodic Reports (M

36、onthly) are run per country to identify name matches between the Watch Lists and Customer Database,Lists of customer names (country / business / Group),WLM Database,Screening Systems Used Customer Screening,36,Source Customer & Counterparty Names Data,Watchlist Management,Analysis & Reporting,Escala

37、tion to Country Compliance and / or Group Sanctions Advisor,Review of Name Matches,Sanctions Screening System,Shared Service Centre,Payment Operations in Country,Messaging System,Review of Name Matches,Payment Operations in Shared Service Centre, Chennai, India,Screening Systems Used Transaction Scr

38、eening and Workflow,Alerts (potential name match),Notification of release / reject,Escalation of alert.,37,Sanctions Guidance GFCR Policies, Procedures and Guidance,38,Sanctions Guidance Key investigation steps,39,Review alert score, the closer the score to 100% the closer the match. Compare alerted

39、 customer / transaction details against watch list entry. For individual customers, compare unique identifying information such as date of birth, passport numbers, fathers name, country of birth, nationality, residence and other background information. For entity customers, compare unique identifyin

40、g information such as incorporation details (i.e. country of incorporation, country of operation) company pro other background information. For payment messages compare address details to determine if it is the same person or entity. Review other background information on watch list entry to see if

41、there is any commonality. If still uncertain can go back to correspondent bank and ask for details.,Sanctions Guidance Escalation process,40,Outlined in Automated Payment Screening Procedure, Group Names Screening Systems Procedure and Group Sanctions Procedure. Group Names Screening Systems Procedu

42、re Steps to be taken if a confirmed match against sanctions list: follow the Group Sanctions Procedure, inform Group Sanctions Adviser immediately of the name match and action taken, procedures require to act as bound by UK law unless there is a conflict with local law, in which case refer to Group

43、Sanctions Procedure.,41,41,41,41,Continuous improvement,Sanctions Enhancement Programme,Internal Internal Audit,Benchmarking through Engagement with industry bodies,FSA Thematic industry review,External consultancy,Internal Periodic policy and procedure reviews by Group Sanctions Advisor & Group Hea

44、d of Systems & Monitoring,Industry Guidance Basle Committee Wolfsberg Group FATF SR7 JMLSG,Name Matching Logic,There are essentially two types of name matching logic: Exact name matching used to perform exact name matching against main watch list entities and aliases. Non exact name matching (fuzzy

45、matching) used to detect non exact name matches against watch list entities and aliases. This includes part matches, name variations, spelling variations and permutations. Specific rules help identify close matches by eliminating spaces, special characters, noise words or by adding synonyms, noise w

46、ords etc. Non-exact name matching increases the level of false alerts, therefore systems need to employ techniques to reduce them such as “exclusion or good guy” lists, noise word suppression etc.,42,Screening System Testing and Tuning,With the help of external consultants, SCB created an independen

47、t testing team to periodically test the effectiveness its customer and payment screening systems. The team creates data files from sanctions lists to test approximately 40 different exact and non-exact name match scenarios. These are then run against the banks sanctions screening systems in a test e

48、nvironment and the output reviewed to identify areas where the systems logic can be enhanced. The general trend is that exact name matching in banks has historically been working effectively, however the level of effectiveness of non-exact name matching is much more varied and there are tests that r

49、equire improvement. Work is continuing to improve these results.,43,44,44,44,44,44,SWIFT MessagesTypes Screened,There are currently 243 SWIFT Message Types (MTs) in use across the industry. Banks may not subscribe to or use all of these and many are not direct payment instructions. Banks have each d

50、ecided for themselves what MTs to screen. SCB risk assesses the SWIFT MTs used by the business and covered by its screening systems and with the assistance of external consultants compares that list to industry peers. As a result a group minimum (containing approx 90 MTs) has been established and sy

51、stems are tuned to include these as a minimum. Systems are updated and aligned as and when policy amended.,45,45,45,45,45,Evaluation of messages rejected,All banks will from time to time have their messages rejected by other banks. It is important to monitor this and take appropriate action to avoid

52、 continuing rejects. The trends that we are seeing are as follows:,Challenges in screening process,Need for detailed information on sanctioned parties in sanctions lists to help decisioning of potential name matches (alerts). Need for accurate and up to date client information to help decisioning of

53、 alerts. Turnround times and client expectations. Common names and false alerts (e.g. Ali Khan on OFAC list) Spelling variations and the risk of missing true alerts.,46,Alternate Spelling Islamic Names,First name - Mohd Iqbal Surname - Abd Al Rahman,395 variations for Mohd,26 variations for Iqbal,22

54、7 variations for Abd Al Rahman,Courtesy: Language Analysis Systems Inc,47,Name variations / aliases,Hotel Booking,Traffic Violation,Criminal Intel File,Cell Phone Co.,The Name Problem: One Name Many Variations,Mustafa Khan Owasi WANTED,Missed at Routine Stop,Moustafa Kan Elowesse (cultural variation

55、 & phonetic variation),Mustaffa Bouasy (cultural variation),Moustafa Abouassi (cultural variation),Mustaffa Kan Owazi (character variation),Mostaffa Ken Abdolwasie (cultural variation & character variation),Moostapha Kanawasi (phonetic variation),Criminal Record File,Courtesy: Language Analysis Syst

56、ems Inc,48,Name Translations,Taiwan,Philippines,Indonesia,Thailand,Cambodia,Myanmar,(Burma),Laos,Vietnam,Hong Kong,Macau,Malaysia,China,Singapore,The Same Name across SE Asia,Courtesy: Language Analysis Systems Inc,49,Name Translations,The Same Name in a Korean Telephone Book,Courtesy: Language Anal

57、ysis Systems Inc,50,51,51,51,Use of codes in messages,Chinese Commercial Code - long standing practice used for official and other purposes. Not to conceal identity but to enable accurate translation. Used to record details of remitter, beneficiary and other payment details in SWIFT messages. Code c

58、ould be used to conceal names of sanctions targets. Screening of code is a challenge.,:72:/REC/CONTINUE ORDERING CUSTOMER /8002 1579 1562 0794 1444 1367/1466 7108 2621 8827 6567 0074,52,52,52,Ongoing Risk Assessment,Ongoing risk assessment / benchmarking against industry to evaluate coverage and det

59、ermine next product / channels to screen. Sanctions risk assessment undertaken with input from the business, operations and Financial Crime Risk (Compliance). Risk assessment looking at product, country and customer, taking into account screenability, volumes and values. Risk assessment of watchlists to stop or trigger enhanced