Benelux forum 2014 - Sanctions Testing

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Presentation from the SWIFT Benelux Forum held in La Hulpe on 19/20 March 2014

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Benelux forum 2014 - Sanctions Testing

  1. 1. Sanctions Testing BENELUX Forum Thomas Preston March 2014
  2. 2. In a world of unprecedented complexity and change: • How can I be sure my screening solution works? • How can I demonstrate I understand my solution and how it mitigates risks? • How can I make my screening solution more effective – and more efficient? Banks face a sanctions compliance challenge
  3. 3. Effectiveness • Provide assurance assurance • that your system works • Measure system’s fuzzy matching performance • Assess coverage of sanctions lists • Align screening system to your risk appetite Efficiency • Reduce false positives through iterative testing • Build optimisation tests into your processes Testing Meeting regulatory demands Tuning Managing cost and resources Sanctions compliance – balancing priorities with
  4. 4. Assessing your environment’s effectiveness • Assurance that your systems work • Measure your fuzzy matching performance • Assess coverage of sanctions lists • Align system with your risk appetite Improving your environment’s efficiency • Reduce false positives through iterative testing • Build optimisation tests into your processes • Develop testing & tuning framework in line needs All of this while maintaining full control over your systems, sanctions and assurance processes. 4 Address regulatory demands Manage cost concerns Sanctions Testing Benefits
  5. 5. Formats Settings Lists Automate • Repeat • Compare • Monitor Sanctions Testing Process Define test objective Download test objective Process test files Upload hit results View test results
  6. 6. • Outdated lists • Missing entry types • Missing entries • Language variants not screened correctly • Deleted records still screened • List scope • incorrect or not aligned with bank policy • Inconsistent implementation across filters • Entity and alias types screened unnecessarily • Inconsistent screening performance across message types • Message or file elements not screened properly • Overreliance on specific fields (e.g. address or country) • Poor fuzzy matching performance • Line break, word order, sequences • Poor performance against particular entries (short or long names, aliases) • Character set matching issues 6 Common issues identified through testing Sanctions Lists Quality Screening Policy Message Types Filter Weakness

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