FINANCIAL CRIME RISK & POLICY
GROUP
Graham Baldock (HSBC, Head of Financial Crime Compliance,
Global Trade & Receivables Finance)
Graham Finding (HSBC, Head of Business Financial Crime Risk,
Global Trade & Receivables Finance)
09 October 2019

WE ARE THE WORLD BUSINESS ORGANIZATION.
CURRENT SCOPE OF WORKING GROUP
1
Financial Crime Risk & Policy Group
• Vessel Checking/Ships going Dark paper
• Compliance in the New Digital Trade Arena (Distributed Ledger Technology) Paper
• Mentoring the Successor in Trade (SIT) candidates - Sanctions Compliance / AML Unusual vs Suspicious
• Letter of Credit Export Advising (Non Customer Counterparty)
• Fraud in Trade Finance
• Tariff Evasion
ACHIEVEMENTS TO DATE
• Alignment of Wolfsberg Trade Finance Working Group and BAFT to the ICC FCRPG
• July 2019. ICC published the Proliferation Financing/Dual Use Goods Paper
• July 2019. ICC published the Price Checking in Trade Finance Paper
STRATEGY GOING FORWARD
• Compliance in the New Digital Trade Arena (Distributed Ledger Technology) paper to be submitted to the ICC for
consideration of publication
• Further engagement with FATF
• Reach out to the International Maritime Organisation (IMO)