Financial Crime Compliance Working Group


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.


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 risk matrix of both traditional and emerging asset classes outlining their different risk factors
  • An updated ISSA Questionnaire as well as FCC Principles document, if necessary

Key Outcomes

  • To ensure that the risk dimensions of different asset classes and new technologies 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



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

Working Group Co-Chairs

Mark Gem, Clearstream
Olivier Goffard, Euroclear

Executive Sponsor

Margaret Harwood-Jones, Standard Chartered Bank

Institutions Represented by Experts in the Working Group

  • Banque Internationale à Luxembourg
  • Citigroup Inc.
  • Cognizant
  • Credit Suisse
  • Deutsche Bank
  • Deutsche Börse Group
  • Euroclear
  • HSBC Holding Plc
  • ISSA
  • JP Morgan
  • Nasdaq Inc.
  • Northern Trust
  • SEB Group
  • SIX Group AG
  • Standard Chartered Bank
  • The Bank of New York Mellon Corporation
  • The Depository Trust & Clearing Corporation
  • The Mauritius Commercial Bank Ltd.
  • UBS Group AG

“All you need to know about FCCPs” video series

Table of contents video
Background of ISSA FCCP
What did ISSA do about it?
How FCCPs line up with similar regulatory norms
Main requirements prescribed by ISSA FCCP
Due diligence
Third party client business