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Financial Crime Compliance Working Group

Purpose

In August 2015, ISSA released 17 Principles for the global community of securities custodians and intermediaries to adopt. These principles aimed to address the critical challenges posed by financial crime, particularly in environments where omnibus and commingled account structures are utilized. The Working Group’s business-as-usual scope includes ongoing reviews of these principles and the related Due Diligence Questionnaire.

Scope

Our activities in 2025 will include a review of the Principles and ISSA Due Diligence Questionnaire to understand whether additional questions need to be added to the ISSA Questionnaire to mitigate the risks posed by emerging asset classes and in the context of the new geopolitical environment.

Additional, in scope topics for 2025 include:

Geopolitical Impacts Forum

The WG will hold periodic meetings to pool and share information on geopolitical impacts including, but not limited to, sanctions compliance risks. This extends beyond the focus areas of the FCC WG activity and will be coordinated with other ISSA WGs.

Sanctions Benchmarking Survey

The WG will create and distribute a sanctions survey to its members. The results of this survey will enable participating organizations to compare their own sanctions management practices against relevant peers. The benchmark survey provides insights into sanctions management across Securities Services organizations globally.

Securities Lifecycle

To develop a securities lifecycle that includes sanctions risks and screening challenges. This information will be used to generate a report offering best practice guidance and outlining a vision for a standardized screening solution.

Key Deliverables

The key deliverables will be:

An updated ISSA FCC Due Diligence Questionnaire
A report outlining the key results of the benchmarking sanctions survey
A best practice paper on securities sanctions screening

Key Outcomes

To have an up to date and complete ISSA FCC Due Diligence Questionnaire that takes into consideration the risk dimensions of the different asset classes
To master the impact of geopolitical risk on financial crime compliance approaches
To promote a better understanding of current practices in sanctions management, identifying actionable opportunities for enhancement,
To ensure that the Securities Services industry is aware of best practice in sanctions screening across all stage of the securities lifecycle and provide guidance on best practice for screening securities

Bulletins

Publications

Principles and Related Documents

ISSA Financial Crime Compliance – Revised Questionnaire (2023) > DOC 2.56 MB
SWIFT KYC Registry Factsheet NBFI (2022) > PDF 30 kB
ISSA Financial Crime Compliance – Revised Questionnaire (ISSA DDQ) version 12/2021 > DOC 3 MB
Examples of Draft Contractual Terms to Support the Implementation of the Principles 05/2019 > PDF 211 kB
Financial Crime Compliance Principles for Securities Custody and Settlement / Background & Overview Document 05/2019 > PDF 574 kB
Financial Crime Compliance Principles for Securities Custody and Settlement / Second Revision 05/2019 > PDF 326 kB
Financial Crime Compliance Principles for Securities Custody and Settlement / Background & Overview Document 10/2015 > PDF 708 kB
Financial Crime Compliance Principles for Securities Custody and Settlement 08/2015 > PDF 290 kB
Discussion paper on Transparency in Securities Transaction and Custody Chains, issued on 22 April 2014, as pre-reading documentation for the ISSA Symposium 17.
> PDF 360 kB

Additional Documents

ISSA Comments to BIS’s consultative document of October 21, 2015 > PDF 414 kB
ISSA commissioned Study on the Benefits and Costs of Securities Accounting Systems, August 20, 2015 > PDF 950 kB