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Financial Crime Compliance Working Group

Purpose

The purpose of the Financial Crime Compliance Working Group (FCC WG) is to foster best practice across a broad spectrum of financial crime-related risks that could arise in the Securities Services industry.

Scope

ISSA Questionnaire and Principles Review

In August 2015, ISSA released 17 Principles which are recommended to be implemented by the global community of securities custodians and intermediaries in order to address the critical challenges posed by financial crime, particularly where omnibus and commingled account structures are used. The WG’s BAU scope includes reviewing these principles, and related Due Diligence Questionnaire, on an ongoing basis.

In 2023, this will include a review of the Principles and ISSA Questionnaire to understand whether additional questions need to be added to the ISSA Questionnaire to mitigate the risks of the different asset classes and in the context of the new geopolitical environment.

Additional, in scope topics for 2023 include:

Asset Class Financial Crime Risk Review

The scope of this subgroup will be to outline the financial crime risk dimensions for different asset classes, from traditional assets to emerging assets such as crypto currencies and digital assets.

Geopolitical Impacts Forum

The WG will create a forum to pool and share information on geopolitical impacts including, but not limited to, sanctions.

Key Deliverables

The key deliverables will be:

A questionnaire outlining the different risk factors for traditional and emerging asset classes
A review of the Principles and ISSA Questionnaire to understand whether additional questions need to be added to mitigate the risks of the different asset classes and new technologies
An updated ISSA Questionnaire

Key Outcomes

To ensure that the risk dimensions of different asset classes are included as part of the due diligence undertaken when assessing existing new and existing clients
To have an up to date and complete ISSA Questionnaire that takes into consideration the risk dimensions of the different asset classes
To master geopolitical impacts on financial crime compliance

Bulletins

Reports

Principles and Related Documents

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