SWIFT Sanctions Screening Assurance

Key Challenges

A bank performs sanctions screening using some third-party software. Although the screening system appears to be working in that output is created, but the bank quite rightly wants to know if its system: addresses the bank’s risk, is effective, is efficient, is comparable to peer banking institutions.

The bank requires:

  •  A benchmark comparison against its peers.
  • Operational effectiveness figures.
  • Operational efficiency figures.
  •  A report showing what risk is not addressed by screening – residual risk.
  •  A report on the screening that can be delivered to regulators.

SQA PROposed solution

SQA Consulting provides a Screening Assurance service based around its product Sanctions Assessment Centre. The Sanctions Assessment Centre has the capability to create test files covering different aspects of banking risk, including:

  • All of the names on sanctions lists
  • Manipulations of names to cover common business scenarios (such as miss-spellings)
  •  Geographic terms from countries of sanctions significance
  •  False-positive tests to establish comparative efficiency
  •  BICs of sanctioned banks
  •  Vessels & Vessel IMO Number of sanctioned vessels.

The Sanctions Assessment Centre has been used at many banks & financial institutions & has an extensive set of benchmark figures. SQA Consulting uses its benchmarking graph which illustrates a comparison of both effectiveness and efficiency, akin to showing cars by top-speed and economy.
The process relies on the bank providing a live-like test environment for SQA Consulting to provide a test file for. SQA created a test file in which each & every SWIFT message had a specific traceable purpose. Each & every tag in each & every SWIFT message included a test to ensure coverage of all messages and all types of data from name specific fields to open narrative.

solution benefits

The observation document produced after the typical 4 weeks since project start, contained observations on screening weakness, with root cause analysis, a recommendation for management, & management responses. A document such as this is exactly what a regulator is looking for, demonstrating that a thorough investigation has been conducted, & any weaknesses have plans for closure.

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