Banks control of financial crime risks in trade finance.

A LexisNexis White Paper The Financial Conduct Authority Thematic Review. Banks control of financial crime risks in trade finance. A summary and highlights of the review and industry challenges by Mark Dunn, Market Planning Manager, Risk & Compliance July 2013

Index 3 Introduction 4 Governance and management information 5 Risk assessment 6 Policies and procedures 7 Due diligence 8 Training and awareness 9 Transaction anti-money laundering controls 10 Sanctions controls 11 Counter terrorist financing (CTF) controls 12 Trade-based money laundering red flags 14 Conclusions LexisNexis has a world-class reputation for providing critical business tools. For over 30 years we have been pioneers in intelligence and risk management. As a digital pioneer, the company was the first to bring legal and business information online with our Lexis and Nexis services. Today, LexisNexis harnesses leading-edge technology and world-class content to help professionals work in faster, easier and more effective ways. Our solutions are used internationally by financial services, legal and accountancy firms and blue chip multinational companies to enhance business decision making, fulfill regulatory requirements and for premium information research. LexisNexis serves customers in more than 100 countries with 10,000 employees worldwide.

In July 2013, the UK Financial Conduct Authority (FCA) published their thematic review Banks control of financial crime risks in trade finance describing how banks in the UK control money laundering, terrorist financing and sanctions risks (collectively financial crime risks ) in trade finance business and setting out the findings from their recent assessment. The FCA s latest review assessed the systems and controls implemented by banks to tackle anti-money laundering and sanctions screening within trade finance. The review was aligned to the scope of the Wolfsberg Trade Finance Principles and focused on the approach taken to finance the movement of goods and services across borders. The review paid specific attention to Documentary Letters of Credit (LCs) and Documentary Bills for Collection (BCs). The thematic review was conducted between September 2012 and February 2013. The FCA met with 17 banks in the UK including 4 major UK banks, 5 global wholesale and investment banks and a number of smaller overseas banks based in London. The FCA also conducted an overseas visit to examine offshore backoffice trade finance processes at three major banks. Overall, the results of the review were considered poor and the report states: The majority of banks in our sample, including a number of major UK banks, are not taking adequate measures to mitigate the risk of money laundering and terrorist financing in their trade finance business. There were some notable exceptions to this, particularly among some of the larger US banks in our sample The FCA press release accompanying the thematic review highlights the following common weaknesses identified by the report: Having no clear policy or procedure documents for dealing with trade-based money laundering risks thus failing to identify potentially suspicious transactions; Producing little or no management information on financial crime risks in the trade finance business; and The majority of banks in our sample, including a number of major UK banks, are not taking adequate measures to mitigate the risk of money laundering and terrorist financing in their trade finance business. Not developing specific training on the risks of crime relating to finance relevant staff. As a result, evidence was found of staff failing either to make appropriate enquiries about financial crime risks or escalating potentially suspicious transactions. Tracey McDermott, Director of Enforcement and Financial Crime at the FCA also comments on the poor report and reminds firms of their obligations: Anti -money laundering measures and sanctions are in place to protect us from criminal activity. Financial institutions need to take this responsibility seriously and we will do whatever is necessary to ensure they do. The full FCA report and press release can be accessed via the following link: http://www.fca.org.uk/news/the-fca-holds-keyconference-on-financial-crime Page 3

Governance and management information Roles and responsibilities for managing financial crime risks in trade finance are clear and documented. There is a failure to produce management information on financial crime risk in trade finance. There is a lack of internal audit focus on financial crime controls in trade finance. The structure and culture of banks do not encourage the sharing of information relevant to managing financial crime risk in trade finance. There is failure to establish appropriate forums to allow knowledge and information sharing about financial crime risk Page 12. Banks control of financial crime risks in trade finance. FCA July 2013 Maintaining comprehensive audit data and access to management information is a prerequisite of any AML and sanctions screening process. Using technology as an enabler to audit due diligence checks, screening processes, escalation and reviews is a primary driver. Solutions should be adopted which provide a thorough audit trail, including enhanced due diligence searches, and have a comprehensive management intelligence function enabling reports to be produced to help demonstrate regulatory compliance, process productivity and return on investment. The FCA review comments positively on the availability of the kind of statistical information that shows potential sanctions hits or escalations of suspect activity by staff. Page 4

Risk assessment Completing a documented financial crime risk assessment for trade finance business that gives appropriate weight to money laundering risk, as well as sanctions risk. Failing to update risk assessments and keep them under regular review to take account of emerging risks in trade finance. Only focusing on credit and reputational risk in trade finance rather than carrying out a proper consideration of financial crime risk. Not taking account of a customers use of the bank s trade finance products and services in a financial crime risk assessment. Page 15. Banks control of financial crime risks in trade finance. FCA July 2013 Keeping the compliance team and key staff updated with changing risk indicators and regulator expectations needn t be a costly and cumbersome exercise. The inability for a regulated firm to maintain its risk assessment process has been highlighted by a number of recent enforcement actions. Regulators expect companies to be aware of changing risks in their markets and to apply a risk assessment process that is agile enough to be amended and updated accordingly. This flexible approach to risk assessment is not only important to take account of ad hoc changes in risks related to specific countries and entities for example, but also to be able to quickly assign risk assessment to the firm s business development strategy and new product adoption etc. Industry best practice recommends the risk assessment be reviewed at minimum annually. However, as mentioned above, many firms need to ensure their risk assessment process is flexible enough to respond to market forces. The FCA review cites a good example of how this process is managed by a sample bank: One major US bank produced a Trade Services AML Risk Assessment document, which was updated annually. The document provided a comprehensive overview of: the bank s trade finance business; the AML and sanctions risks involved; the bank s exposure to those risks; and the controls around them. Various appendices to the document provided a wealth of useful additional information, including a long list of Trade Services red flags, annotated to show what certain red flags might indicate. This document had also proved to be a useful tool for educating senior managers about the technicalities of trade finance. Page 5

Policies and procedures Staff are required to consider financial crime risks specific to trade finance transactions and identify the customers and transactions that present the highest risk at various stages of a transaction. Staff are required to screen all relevant parties to a transaction. Very little money laundering guidance on financial crime risks specific to trade finance. Staff are not required to consider trade specific money laundering risks (e.g., FATF/Wolfsberg red flags). Procedures do not take account of money laundering risks and are focused on credit and operational risks. No clear escalation procedures for high-risk transactions. Procedures fail to take account of the parties involved in a transaction, the countries where they are based and the nature of goods involved Page 17. Banks control of financial crime risks in trade finance. FCA July 2013 The unique factors associated with trade finance transactions need to be reflected in firms policies and procedures with staff fully aware of the obligations in this area The FCA review is critical of firms which applied generic AML and sanctions risks to trade finance and did not take into account specific red flags and industry guidance in this area of the business. Appendix I of the thematic review contains a lengthy list of typical red flags associated with trade finance transaction (also referenced on page 14 of this white paper). Another factor is the requirement to have in place a robust escalation process to ensure any high risk or suspicious transactions received prompt attention from compliance. As mentioned above, solutions should be adopted which can implement an effective escalation process. Page 6

Due diligence Banks procedures are clear about what checks are necessary and in what circumstances for non-client beneficiaries (or recipients) of an LC or BC. Written procedures do not make it clear what due diligence must be carried out on the instructing parties to an LC or BC depending on the bank s role in a transaction. Trade processing teams do not make adequate use of the significant knowledge of customers activity possessed by relationship managers or trade sales teams when considering the financial crime risk in particular transactions. Lack of appropriate dialogue between CDD teams and trade processing teams whenever potential financial crime issues arise from processing a trade finance transaction. Page 21. Banks control of financial crime risks in trade finance. FCA July 2013 A primary goal for the compliance function is to have a consistent approach to onboarding which ultimately improves customer service and provides a competitive edge. By auditing the local and international systems used for third party due diligence, the business is able to demonstrate consistent compliance. Risk solutions from LexisNexis enable approval of new third parties at the appropriate level and escalation to senior management for review when needed. All information gathered on an entity can be collated into one file and forwarded together with any notes, providing an efficient and auditable review process. A separate file is created for all PEPs and high risk entities, making closer ongoing monitoring straight forward and routine. It is possible to allow Business Managers minimal privileges and for any red flags to automatically drive escalation to Compliance, ensuring an appropriate risk-based approach at each stage. Using PEP databases in isolation is not sufficient and broader news checks are needed to clearly identify associations and other high risk indicators. Building an end-to-end workflow that looks across broader data sets also ensures ongoing monitoring is regular and efficient. By seamlessly combining the initial onboarding process with an ongoing monitoring process, all alerts can be handled in the same manner and a consistent approach is guaranteed. Page 7

Training and awareness Providing tailored training that raises staff awareness and understanding of tradespecific money laundering, sanctions and terrorist financing risks Using relevant industry publications to raise awareness of emerging risks. Only providing generic training that does not take account of trade-specific risks (e.g. FATF/ Wolfsberg red flags). Failing to roll out trade specific financial crime training to all relevant staff engaged in trade finance activity, wherever located. Relying on experienced trade processing staff who have received no specific training on financial crime risk. Page 24. Banks control of financial crime risks in trade finance. FCA July 2013 Applying consistent, up to date and tailored training is essential to ensure staff remains fully aware of their individual roles & responsibilities both regulatory and ethical. The onset of poor practices is more common when resources are tight and adequate support is not offered to the compliance function. LexisNexis works with thousands of financial institutions of all sizes, offering scalable solutions that meet the needs and budgets of most organisations. Increasingly organisations are being more selective in their use of different training materials and technology to deliver updates to staff. Training and tutorials that are targeted to the requirements of specific personnel and the risks they manage can be delivered via short webinar updates and supplements to the comprehensive training undertaken by staff when they join the firm. For example, the definition of a PEP is not consistent across all jurisdictions so it is key that careful attention is given to this area. LexisNexis supports this by separating PEPs into the relevant categories to ensure only the most relevant matches are delivered. Domestic PEPs can be switched on or off as needed, however there is a growing trend to include them as standard. When multiple systems are deployed gaps in the AML process can be unavoidable. We help our clients ensure they have a consistent end-to-end process based on a single platform. Page 8

Transaction anti-money laundering controls A formal consideration of money laundering risk is written into the operating procedures governing LCs and BCs. The money laundering risk in each transaction is considered and evidence of the assessment made is kept. Detailed guidance is available for relevant staff on what constitutes a potentially suspicious transaction, including indicative lists of red flags. Level 1 trade processors are employed with good knowledge of international trade, customers expected activity and a sound understanding of trade-based money laundering risks. Processing teams are encouraged to escalate suspicions for investigation as soon as possible. Those responsible for reviewing escalated transactions have an extensive knowledge of trade-based money laundering risk. Underlying trade documentation is obtained and reviewed wherever possible. Analysis of pricing for those goods where reliable and up-to-date pricing information can be obtained. Regular, periodic quality assurance work is conducted by suitably qualified staff that assess the judgments made in relation to money laundering risk and potentially suspicious transactions. Where red flags are used by banks as part of operational procedures, they are regularly updated and easily accessible to staff. Expertise in trade-based money laundering is held in a department outside the trade finance business (e.g., compliance) so that independent decisions can be made in relation to further investigation of escalations and possible SAR reporting. 34-35. Banks control of financial crime risks in trade finance. FCA July 2013 Failing to assess transactions for money laundering risk. Relying on customer due diligence procedures alone to mitigate the risk of money laundering in transactions. Relying on training alone to ensure that staff escalate suspicious transactions, when there are no other procedures or controls in place. Disregarding money laundering risk when transactions present little or no credit risk. Disregarding money laundering risk when transactions involve another group entity (especially if the group entity is in a high risk jurisdiction). Focusing on sanctions risk at the expense of money laundering risk. Failing to document adequately how money laundering risk has been considered or the steps taken to determine that a transaction is legitimate. Using trade-based money laundering checklists as tick lists rather than as a starting point to think about the wider risks. Failing to investigate potentially suspicious transactions due to time constraints or commercial pressures. Failing to ensure that relevant staff understand money laundering risk and are aware of relevant industry guidance or red flags. Failing to distinguish money laundering risk from sanctions risk. Having ambiguous escalation procedures for potentially suspicious transactions, or procedures that only allow for escalation to be made to sanctions teams. Not taking account of other forms of potentially suspicious activity that may not be covered by the firm s guidance. Failing to make use of information held in CDD files and RMs knowledge to identify potentially suspicious transactions. Not giving trade processing teams sufficient time to fully investigate potentially suspicious activity, particularly when there are commercial time pressures. Failing to make use of third party data sources where available and appropriate to verify information given in the LC or BC. Not encouraging trade processing staff to keep up-to-date with emerging trade based money laundering risks. Implementing consistent and robust procedures for trade finance transactions is an essential part of an AML process. The FCA stresses the importance of having in place effective due diligence and associated approval processes for trade finance transactions. Clearly documented and communicated procedures are also highlighted by the FCA. In addition, a thorough audit trail should be a prerequisite for any trade finance AML process. Enabling Compliance to be able to follow the paper trail is critical should a suspicious payment require further investigation or to allow the firm to simply demonstrate to supervisory authorities examples of what payments were made and why to a particular third-party. This should be supported by regular reviews and ad hoc spot checks to ensure the payment controls in place continue to remain robust and appropriate to the firm s business and its riskbased approach to trade finance. Such reviews, accompanied by effective management intelligence, will also enable the firm to identify and consider potential improvements in the trade finance AML process bringing valuable benefits to the overall business. Page 9

Sanctions controls Screening information is contained within trade documents against applicable sanctions lists. Hits are investigated before proceeding with a transaction (for example, obtaining confirmation from third parties that an entity is not sanctioned), and clearly documenting the rationale for any decisions made. Shipping container numbers are validated. Potential sanctions matches are screened for at several key stages of a transaction. The review of certain types of potential matches is prioritised following analysis of previous sanctions alerts. Staff dealing with trade-related sanctions queries are not appropriately qualified and experienced to perform the role effectively. Failing to screen trade documentation. Failing to screen against all relevant international sanctions lists. Failing to keep up-to-date with the latest information regarding name changes for sanctioned entities, especially as the information may not be reflected immediately on relevant sanctions lists. Failing to record the rationale for decisions to discount false positives. Automated screening is supplemented by considering the sanctions issues as part of trade processing procedures. Ensuring new or amended information about a transaction is captured and screened Failing to undertake screening for agents, insurance companies, shippers, freight forwarders, delivery agents, inspection agents, signatories, and parties mentioned in certificates of origin where this information is available, as well as the main counterparties to a transaction. Page 38. Banks control of financial crime risks in trade finance. FCA July 2013 Given ongoing enforcement and severe penalties for poor sanctions controls, it is critical firms continue to review processes and remain aligned to regulators expectations Few financial institutions need to be reminded of the importance of implementing and maintaining a robust sanctions screening process. Fewer areas dealing with tackling financial crime have come under more scrutiny in recent years than compliance with national and international sanctions regimes. The FCA review reflects many of the essential elements expected of firms in this area including staff sufficiently qualified to manage such a process, ensuring all relevant lists are screened, maintaining current awareness of sanctions issues within markets and applying robust escalation procedures and auditing decisions taken etc. Regarding international measures to implement and maintain effective sanctions regimes, the recent FATF guidance updates current thinking in this area: International best practices. Targeted financial sanctions related to terrorism and terrorist financing (Recommendation 6) (FATF, June 2013) http://www.fatfgafi.org/media/fatf/documents/recommendations/bp P-Fin-Sanctions-TF-R6.pdf Page 10

Counter terrorist financing (CTF) controls Attempting to identify dual-use goods in transactions wherever possible. Failing to attempt to identify dual use goods in transactions. Ensuring staff are aware of dual-use goods issues, as well as common types of goods which have a dual use. Confirming with the exporter in higher-risk situations, whether a government licence is required for the transaction and seeking a copy of the licence where required. Focusing purely on military or lethal end use goods. Not having a clear dual-use goods policy. Failing to undertake further research where goods descriptions are unclear or vague. Not making use of third-party data sources where possible to undertake checks on dualuse goods Page 40-41. Banks control of financial crime risks in trade finance. FCA July 2013 The inherent risks of facilitating transactions involving dual use goods is a critical factor to consider within trade finance Counter terrorist financing and the risk of inadvertently facilitating the development of weapons of mass destruction has long been a key focus of United Nations Resolutions and ensuing sanctions. The FCA report reminds firms of the unique challenges in handling business risks in this area and in identifying potential high risk goods. The threat of such weapons proliferation remains as acute as ever as reflected in the recent FATF guidance on the subject: The Implementation of Financial Provisions of United Nations Security Council Resolutions to Counter the Proliferation of Weapons of Mass Destruction (FATF, June 2013) http://www.fatfgafi.org/media/fatf/documents/recommendations/gui dance-unscrs-prolif-wmd.pdf Page 11

Examples of trade-based money laundering red flags Banks control of financial crime risks in trade finance The FCA review also includes a useful Appendix that lists examples of trade-based money laundering red flags: Customer red flags The customer wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the customer s stated business strategy (eg, a steel company that starts dealing in paper products, or an information technology company that starts dealing in bulk pharmaceuticals). A customer significantly deviates from their historical pattern of trade activity (ie, in terms of value, frequency or merchandise). Transacting businesses share the same address, provide only a registered agent s address, or have other address inconsistencies. Pre-accepted discrepancy(s) by the applicant and/or the applicant is over-keen to waive discrepancy(s). Excessive/aggressive/pressured contact by the client. Customer is reluctant to provide clear answers to routine financial, commercial, technical or other questions. Page 46. Banks control of financial crime risks in trade finance. FCA July 2013 Document red flags Shipment locations of the goods, shipping terms, or descriptions of the goods are inconsistent with the Letter of Credit. This may include changes in shipment locations to high risk countries or changes in the quality of the goods shipped. Significant discrepancies appear between the descriptions of the goods on the bill of lading (or invoice) and the actual goods shipped. Applicant-issued documents called for in the letter of credit. Unauthorised alterations/amendments to documents. Beneficiary or applicant refuses to provide documents to prove shipment of goods (possible phantom shipping or multiple invoicing). Bill of lading consigned: to be advised between applicant and beneficiary. Consignment should be to a named party (usually the Applicant, Broker, Bank or to the order of shipper blank endorsed). Bill of lading describing containerised cargo, but without container numbers or with sequential numbers, non-standard numbers or indicates IRISL (Iran) prefix. LC includes a condition for a switch bill of lading. Unusual codes, markings or stamps appear on monetary instruments, such as drafts or bills of exchange. Re-presentation of an official document immediately after a turn-down for discrepancy. Re-presentation of any shipping documents that were rejected because of US sanctions. Obvious alterations to third-party documents, e.g., bills of lading, customs forms. Future dated bills of lading. LC received as unauthenticated SWIFT or untested telex message. Pages 46-47, Banks control of financial crime risks in trade finance. FCA July 2013 Page 12

Transaction red flags Transaction structure appears unnecessarily complex and designed to obscure the true nature of the transaction. The LC contains non-standard clauses, or phrases such as: - request to issue a ready, willing and able message, or a letter of interest - LC is unconditional, divisible and assignable - transactions requiring proof of product - funds are good, clean and cleared, of non-criminal origin - bearer instrument letter of credit, or - transferable and assignable without being used. The transaction is an offshore shipment (e.g., buyer/seller located in USA, while movement of goods occurred offshore of USA). A party to a transaction is a shell company. Transaction involves an unusual intermediary or number of intermediaries. Approach from previously unknown party whose identity is not clear, who appears evasive about their identity or connections or whose references are not convincing. Significantly amended letters of credit without reasonable justification or changes to the beneficiary or location of payment. Any changes in the names of parties also should prompt additional OFAC review. Page 47, Banks control of financial crime risks in trade finance. FCA July 2013 Payment red flags Unexplained changes to payment instructions. Request to pay a third party. The transaction involves the receipt of cash (or other payments) from third party entities that have no apparent connection with the transaction. Changing the LC or BC place of payment, e.g., payment is to be made to beneficiary s account held in another country other than the beneficiary s stated location. Unusually favourable payment terms, such as payment substantially far above or below expected market price, interest rate substantially far above or below known prevailing rate, or lump-sum cash payment. The transaction involves an unusual trigger point for payment (e.g., before goods are shipped, with no documentation required). Changing the LC beneficiary or BC payee name and address just before payment is to be made. Including requests for assignment of proceeds or transfer at the time documents are presented. LC or BC purportedly covers the movement of goods but fails to call for presentation of transport documents. LC covers steel shipment but allows a forwarder s cargo receipt (FCR). Page 48, Banks control of financial crime risks in trade finance. FCA July 2013 Page 13

Shipment red flags Trade transactions where the quantity of goods exceeds the known capacity of the shipping containers or the tanker capacity. Or where abnormal weights for goods are suspected. The shipment does not make economic sense. For example, the use of a forty-foot container to transport a small amount of relatively low-value goods. Shipping documents show weights and measures inconsistent with the goods shipped or method of shipment. Page 48, Banks control of financial crime risks in trade finance. FCA July 2013 Conclusions from the Thematic Review Our main conclusion is that the majority of banks in our sample, including a number of major UK banks, are not taking adequate measures to mitigate the risk of money laundering and terrorist financing in their trade finance business. There were some notable exceptions to this, particularly among some of the larger US banks in our sample. Most banks need to conduct significant work to ensure that all financial crime risks are routinely considered when processing transactions. In particular, staff responsible for managing financial crime risks required better training to identify potentially suspicious transactions. More work is required at most banks to ensure high-risk customers and transactions are identified and appropriate action is taken by senior management. In addition, banks generally need to improve management information so that senior management are aware of how financial crime risks are evolving in this type of business. Where banks fell short of our regulatory requirements, we have highlighted the areas where they need to improve. We are also considering where further regulatory action may be required for certain banks in our review. Page 6, Banks control of financial crime risks in trade finance. FCA July 2013 Unsurprisingly, given the failings identified by the FCA and highlighted in their report, the press release that announced the Thematic Review hints at possible future enforcement action being taken against some of the 17 firms sampled: We are considering whether further regulatory action may be required in relation to certain banks in the review. Tracey McDermott, Director of Enforcement and Financial Crime Division, adds: We will include these examples of good and poor practice in our regulatory guidance, to Financial Crime: A Guide for Firms. If you have any comments on the proposed examples of good and poor practice in this report, please respond to our consultation. Page 14

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