渣打银行制裁合规_管理框架.ppt

* Ongoing Assurance * Ongoing Assurance * * Can be started after US BR4 implementation has reached stability Countries have been paired based on source systems similarity Reduce testing effort Maximizes efficiencies * * * * * * * Note : Source August 2006 Celent, the international financial services analyst group report. Independent Evaluation * * Country Categories A B C D Characteristics: Business Size – current future, product risk Financial Crime Risk Profile Regulatory requirements /expectations Large Significant Demanding Small Varied Demanding Varied Varied Low/None Very Small Low Low/None Response Specialist TM Solution Specialist TM Solution Enhanced Exception Reports No Technology Enhancement Automated Transaction Monitoring Approx. 20 Countries Representative Offices All other Countries FCR System Strategy * * Is there an AML law in place in? Is there a Financial Intelligence Unit? Are there any explicit legal or regulatory requirements for banks to implement a specialist AML system? Are they expectation sometime soon in the future? What is the local financial crime risk profile, international risk rating? What is the size of the business, likely future growth and the strategic significance to the rest of the Group? Are there any operational factors that may limit or assist the implementation (e.g. expected connection to the Group Data Warehouse? Can alerts be investigated in a Shared Service Centre?) Do local competitors (including foreign Banks) have specialist AML systems in place? Where there any Internal / External Audit / Regulatory findings criticising the existing transaction monitoring capabilities. Key Considerations for TM * * Watchlist Evaluation * Initial focus: Regulatory list consolidator Politically Exposed Persons (PEP) list Additional services: Adverse media Key / trigger word lists Foreign language capability Regional expertise Internal delivery mechanism Manual lookup Back end integration / connection Automated upda