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Financial Crime Compliance Working Group

Scope

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 Working Group also aims to foster best practice across a broad spectrum of financial crime-related risks across the industry. It is currently focused on advising members of best practice in the fields of payment transparency, sanctions screening, AML risk assessment and monitoring.

Working Group Co-Chairs

Mark Gem, Clearstream
Olivier Goffard, Euroclear

Milestones

During 2021, The Financial Crime Compliance Working Group is focussed on the following key topics:

FCC Principles Questionnaire: The review of the ISSA Questionnaire has been completed. An FCC Bulletin will be published in Q4 to communicate the changes, along with the new Questionnaire. The FCC Working Group is also working with SWIFT to embed the ISSA Questionnaire in the SWIFT Registry. Other registers will also be provided with the updated Questionnaire.
Collective Investment Schemes: The Working Group has undertaken a review of the compliance of CI Schemes with the objective of providing guidance on financial crime compliance for these instruments.
Payment Transparency: The Working Group’s existing conclusions on payment transparency will be integrated into a more general discussion at the ISSA Operating Committee level of the future evolution of securities related cash transfers.

Bulletins

Reports

Principles and Related Documents

ISSA Financial Crime Compliance Principles for Securities Custody and Settlement, second revision (05/2019)
> PDF 326 kB
ISSA Financial Crime Compliance Questionnaire (ISSA DDQ), simplified version (05/2019)
> DOC 300 kB
Examples of Draft Contractual Terms to Support the Implementation of the Principles (05/2019)
> PDF 211 kB
Background & Overview on the Financial Crime Compliance Principles (05/2019)
> PDF 574 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