SWIFT Benelux Forum

23 April 2015

The world of compliance

Samir El –Ouahabi, Commercial Manager, AML& Sanctions Solutions, SWIFT

Michel Pronce, Key Clients Service Manager, EMEA, SWIFT

Objective

• Raising awareness of Compliance matters within financial institutions

(the objectives, the actors, the threats, the responses, etc) in an interactive

way with peers.

The world of Compliance – Confidentiality: internal 2

3

The World of

Compliance Rules

The Authorities

The facilitators are the highest level of decision regarding the course of the activity

and the interpretation of the rules.

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The Participants Profiles cards

Each participant has a profile card with:

• The participants mission

• His/her area of responsibility in the 6 steps process

• Some hints for decision making

• Reminder for a few acronyms

• A post it to log some of the encountered challenges

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KYC Responsible

6

Customer

identification

& verification

Initial due diligence

Customer screening

Ongoing due diligence

Customer & transaction monitoring

Transaction screening

start transacting

On-boarding process Ongoing reviews

YOUR MISSION:

Ensure your institution investigates, establishes and monitors solid and trustable business relationships in respect of KYC related principles and regulation.

USEFULL ACRONYMS: AML: Anti Money Laundering CDD: continuous due diligence KYC: Know Your Customers PEPs: Politically Exposed people UN: United Nations

HINTS:

- New/updated PEP?

- Usable Info about Customer business

- Usable info for CDD

- When is it applicable?

CHALLENGES:

The playing field – Turns & Domains

7

1 – Take & read a card

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Information cards vs Decision cards

Card C1.1

means

Turn-1,

card-1

Card C1.3

means

Turn-1,

Card-3

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2 – Agree where to place the card

IF NOT A DECISION CARD:

Place the card on one slot of the current turn (column), in the most appropriate area of responsibility (line)

based on the card text

IF THE CARD IS A DECISION CARD:

– If the Team accepts the proposed action, the card is placed on the DECISION line at the slot

corresponding to the current turn.

– If the Team rejects the proposed action, the card is placed under another card on the board being the

reason of the rejection. (e.g. an actor of the decision card is under sanctions => place the decision card

under the card mentioning the sanction)

Hint: Some card fit in several slots. Chose the most appropriate one.

Hint: Different Decision cards could be rejected for the same reason.

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3 – Place & take accountability

Compliance – Back to the Future – 24 and 25 November 2014 – Confidentiality: internal 11

Accepted

Rejected 3 – Place & take accountability - Decision

4 – repeat until all cards are played

• Pay attention to the sequence of the cards, ensure they go C1.1, C1.2, C1.3,

C2.1, C2.2, etc

• Hints:

– Info from the press: press info not useable in compliance process.

– Info to/from Regulators/Authorities: e.g. updated legal obligations

– Sanctions list Mgt: e.g. new/updated sanction list

– AML: Info to refine transaction monitoring/filtering in AML system

– KYC: info to add/update PEPs records or info qualifying existing/prospect

customers

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5 – Audit

External audit – On facilitator announcement

The auditors shift of table clockwise. The scenario solution is revealed.

The auditor counts and reports the compliance score and the business score

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THANK

YOU

Thank You …. And now,

Time to start, Interact & have fun