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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

In scope topics for 2026 include:

Completion of the Securities Lifecycle effort
Instrument Type Classification

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.

Instrument Type Classification

To provide guidance around the classification of instrument types. The effort will focus on the characteristics of securities from a risk perspective and on the riskiest instrument types. It is expected that the subgroup looks primarily at unregulated and lightly regulated instruments.

Key Deliverables

The key deliverables will be:

Adding the updated ISSA FCC Due Diligence Questionnaire to the CODUDE and SWIFT platforms
Completing a best practice paper on securities sanctions screening
Creating a strawman of key characteristics. To then map the strawman against different instrument type

Key Outcomes

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 Questionnaire (FCC DDQ) ->link
Watch Ivan Nicora, Executive Sponsor for the Financial Crime Compliance WG ->link
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