Financial Crime Compliance Working Group


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


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. 



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

Institutions Represented by Experts in the Working Group

  • Banque Internationale à Luxembourg
  • BNY Mellon
  • Citibank
  • Clearstream
  • Commonwealth Bank of Australia
  • Credit Suisse
  • Deutsche Bank
  • Deutsche Börse Group
  • DTCC
  • Euroclear
  • HSBC
  • ISSA
  • Mauritius Commercial Bak
  • SEB
  • SIX
  • Standard Chartered Bank
  • UBS
  • Winterflood Securities

“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