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SWIFT On Compliance
Luc Meurant, Head of Banking Markets and Compliance at SWIFT
Polling Question #1
What is the level of difficulty for your bank to obtain KYC-related information from your counterparties/correspondents?
A. Not difficult at all – we have a clear process in place and our correspondents always provide the information we need
B. It’s not my area, so I don’t worry about it
C. it’s one of the most challenging aspects of being a correspondent bank
Polling Question #2
How satisfied are you with the quality of KYC-related data that your firm has?
A. The data quality is superb – we have all of the details we need and we receive them on a timely basis
B. The data could use some work, however we are making progress
C. The data is incomplete and out-of-date – a true challenge
Polling Question #3
Are you aware of the SWIFT KYC Registry?
A. Yes, fully aware and understand all aspects of the initiative
B. I have heard about it but don’t know the details
C. I don’t know anything about it…enlighten me!
The SWIFT KYC Registry
6
A community issue calling for a community
solution …
Financial crime is top of
the agenda for banks
Significant costs
at stake…
All geographies / All types of
players impacted
... Yet no competitive
advantage for banks
Lots of duplication,
for universal challenges
Community-inspired financial crime
compliance solutions
Sanctions
Screening
Hosted solution for
cost-effective
compliance with
sanctions
regulations.
All financial message
formats
35+ global sanctions
lists
325 customers in 107
countries
17 central banks
Sanctions
Testing
Maximise the
effectiveness and
efficiency of your
sanctions
environment.
Independent assurance
that your sanctions
filters work correctly
Greater control over
systems/processes
Peer benchmarking
The KYC
Registry
One global source
of KYC information
for correspondent
banking.
Simple, secure,
standardised
Supported by world’s
largest correspondent
banks
SWIFT Profile
Compliance
Analytics
Enhanced
understanding &
management of
financial crime-
related risk.
Unique, global dataset
Interactive investigation
tool
Packaged reports
Event-driven alerting
2013
Dedicated
compliance unit
2014
Compliance
Analytics
2015
The KYC
Registry
Sanctions list mngt service
FATF 16 information
quality
Client/ Name
screening
AML Services
SWIFT 2020 2012
Sanctions Screening
Sanctions Testing
Moving toward a Utility Vision
Today’s market: An unprecedented challenge
to comply with KYC requirements
KYC Utility Complex and
inconsistent requirements
across jurisdictions
Cumbersome, repetitive
and inefficient bilateral
exchanges
Unavailable and poor
quality of information
Increase in pressure to reconcile & ‘de-risk’
Increase in AML/KYC fines (>$3 billion/2 years)
Increase in KYC complexity: FATF/FATCA
The Cost of FI KYC is becoming prohibitive
As a result the industry has witnessed a new development: the growth of the KYC ‘utility ’
Customer ID
Customer base
Ownership
Management
Compliance /AML
FATCA
95+ data points
30 Documents
Secure
Workflow tools
Notifications
Easy to use
Export/ Report
Comprehensive
Fact-based
Ex-industry
professionals
Multiple quality
checks of data and
documents
CDD data*
EDD data*
SWIFT
Profile for
‘KYCC’*
7000+ correspondent
banks use SWIFT
1.3M+ connections
SWIFT National
Commnunities
Development banks
Working Group
The KYC Registry: Single source of directly
sourced, validated KYC data for
correspondent banking
1 Standard
data set
2 Feature-rich
platform
3 Validated
data
4 Unique
content
5 Community-led
* CDD = Customer Due Diligence * EDD = Enhanced Due Diligence * KYCC = Know your customer’s customer
A standard set of KYC data
Category I - Identification of the customer Licenses and Proof of Regulation, Certificate of Incorporation, et cetera
Legal name, auditor, regulator, addresses
Category II – Ownership and management structure Declaration of UBO and shareholders >10%: full names and identifying data
Board of Directors Lists: full names and identifying data
Group structure
Annual Reports, Shareholder listings, certif ied group and organisational charts
Category III – Type of business and client base Revenue breakdow n by legal entity
Operating geographies and customer verticals
Category IV – Compliance information Enhanced AML Questions
AML docs: e.g. AML Controls, Wolfsberg Questionnaire, US Patriot Act
Category V – Tax information TIN, GIIN,FA TCA information & proof of registration, documentation
Manage, collect and share your KYC data in
a single place
User-controlled access Portfolio & task management Export, report and audit User-to-user communication
The KYC Registry platform: feature-rich to improve cost-efficiency and
effectiveness in managing your KYC data
The SWIFT Profile: unique (KYCC) content
What it does
Provides transparency about a bank’s SWIFT network traffic by indicating payments to/from countries that are
considered to be high-risk by FATF or are under EU or OFAC sanctions
Key benefits
Unique insights into a bank’s true payments activity, providing hard data to substantiate declared behaviour
What you get
Aggregate view of incoming and outgoing high-risk payments, traffic analysed by volume and amount
YOUR CORRESPONDENT
COUNTRY OF YOUR CORRESPONDENT’S COUNTERPARTY
YOUR CORRESPONDENT’S DIRECT EXPOSURE
YOUR CORRESPONDENT’S INDIRECT EXPOSURE
PUBLISHER OF THE SWIFT PROFILE CONSUMER OF THE SWIFT PROFILE
YOU
COUNTRY OF ORDERING / BENEFICIARY PARTY’S BANK
KYC Registry14 Apr 2015
358 entities
in 109 countries
Polling Question #4
…So, are you ready to embark on your journey to the KYC Registry?
A. Yes, sign me up today!
B. We plan to implement in the next 3-6 months
C. This is a project for 2016
D. We don’t plan to participate
Thank you