Objective
A leading international bank had already implemented a sanctions screening tool. The compliance department needed an expert for economic sanctions to analyse and evaluate the generated hits. Because it was possible to come across sanctioned persons or organisations, a diligent analysis based on the internal corporate policies and external legal requirements was necessary.
Execution
The cases to be investigated referred to various banking products and international clients. Knowledge of internal guidelines as well as external legal requirements and compliance of tight editing windows were essential demands for editing case-by-case decisions. At the same time, all investigative measures and decisions had to be documented, so that they were relatable to the board of managers as well as auditors. An ongoing communication and the exchange with the various compliance departments (e.g., compliance advisory, attorney team) was a crucial factor for a successful collaboration.
In an ad-hoc project, a process documentation for the processing of sanction incidents regarding Belarus was issued, to legally enable all alert handling, first and second line of defence, personnel.
Result
Through a detailed and meticulous analysis, the client was able to significantly reduce the number of alerts. As a result, the risk of underwriting or maintaining undetected culpable commercial operations with sanctioned persons or companies was reduced significantly. Above that the company is now equipped with a detailed process description for the handling of exceptional cases, regarding payment transactions to Belarus.
