War in Ukraine: A Battle Test for Sanctions and Financial Crime Compliance
At Celent’s annual Innovation and Insight event, we assembled experts (Dan Tannebaum, Paul Mee, Jamie MacGregor, Rob Norris and Gareth Lodge) from across Oliver Wyman and Celent to explore the priorities facing operations and technology executives in helping financial services firms navigate this fast-moving geopolitical moment.
Among the challenges, the extensive international sanctions against selected Russian banks, corporations, and individuals serve as a potent reminder of the need for agility in financial crime compliance.
Applying sanctions is a business-as-usual activity at banks, but a complex one that involves data, technology systems, and operational controls. And, while the immediate focus for financial crime compliance is on screening, a coordinated approach across know your customer (KYC), onboarding, and transaction monitoring functions is needed to make sure the bank is not doing or enabling business with sanctioned entities.
The sweeping nature of the sanctions against Russia will test firms’ ability to apply consistent measures across departments and jurisdictions. Large financial institutions servicing international markets will need to confirm they meet the myriad sanctions issued by the US, UK, European Union countries, Japan, and other jurisdictions globally. Institutions active in multiple lines of business will need to adhere to specific sanctions affecting insurance and capital markets, in addition to banking.
Banks need to ensure they can monitor payments and transfers so they don’t let sanctioned entities or frozen funds slip through. Updating government sanctions lists is the most straightforward task. Banks also need to review their regional coverage for corporate data—to help identify beneficial owners—adverse media, and other datasets used for know your customer scrutiny.