…as they relate to all regulated financial services.
The Commissions banking business themed visit summary findings issued in August 2014 are a pertinent read for other regulated financial service businesses. Sadly a fact over looked by much of the industry.
In regard to Sanctions the particular deficiencies identified are probably endemic in all regulated businesses’ the a greater or lesser degree – these deficiencies being
In- effective governance and oversight by senior managers,
- staff training,
- customer screening,
- fuzzy matches and
- Potential target name matches.
As you can see all of these matters are just as important to trust company, investment and fund businesses. There are valuable lessons to be learned.
Other matters highlighted included
- Poor practice highlighted senior management placing blind reliance on systems and not being able to effectively overseeing the monitoring arrangements.
- There were instances when the BRA lacked sufficient detail adequately considering sanctions risks or sufficient workings of screening and monitoring arrangements.
- There was a lack of specialist training and guidance provided to staff required to investigate potential financial sanctions target name matches.
- Reliance on commercially available screening without a proper understanding of its coverage and failing to adequately consider associated parties and
- Poor practice highlighted that no rationale was recorded when discounting name matches or regular sampling.
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