SWIFT Compliance Services Overview Julien Laurent SWIFT Financial Crime Compliance Division

SWIFT Compliance Services Name Screening Sanctions Screening Sanctions Testing List Management Get support throughout the compliance and financial crime control process Transaction & customer screening Customer due diligence Customer screening Start Business Behavioral monitoring Compliance Analytics Payments Data Quality RMA / RMA Plus Bankers World Online Name Screening Leveraging more than 40 years of innovation and expertise, SWIFT’s comprehensive suite of financial crime compliance products enables you to set the standard in operational insight, transparency and regulatory compliance. Ongoing due diligence The KYC Registry The KYC Registry

SWIFT Compliance Services Get support throughout the compliance and financial crime control process Customer due diligence Customer screening Compliance Analytics Payments Data Quality Bankers World Online Name Screening The KYC Registry

Drive Adoption Promote Standards Design Roadmap Validate Features Explains that SWIFT did not just invent this and decided content and approach by itself, but that we listen(ed) to the community when we decided about content, marketing approach, features, the whole process This is ongoing, we meet UG banks every 6 months to fine tune the offering based on feedback provided by the industry – our owners!

Category I - Identification of the customer Legal name, auditor, regulator, addresses, industry classification (SIC / NAICS) Licenses incl passported licences, proof of regulation, certificate of incorporation and similar documentation Category II – Ownership and management structure Declaration of key UBO and shareholders: Full names and identifying data, incl bearer shares, trusts and foundations Board of Directors Lists: Full names and identifying data Group structure Key financial data, annual reports, shareholder listings, certified group and organisational charts Category III – Type of business and client base Customer base, products offered incl downstream clearing, nested accounts, MSB services Operating geographies, revenue by segment/country, sanctions Category IV – Compliance information CDD & EDD AML questionnaire incl policies & procedures, oversight & controls, ABC policies, screening, monitoring AML docs: e.g. AML Controls, the NEW Wolfsberg 2017 Due Diligence Questionnaire, US Patriot Act Category V – Tax information TIN, GIIN,FATCA information & proof of registration, CRS status & certification, supportive documentation Introduction to content. Repeats the confidential nature, and that SWIFT verifies Important points are that all data comes for the bank in question (it is not a random collection of data from unknown sourses) Mention that we will have the new Wolfsberg from September! “The KYC Registry baseline v.2.0 covers more than 90% of our current KYC requirements. We expect to see significant cost savings over and above the existing efficiency gains.” Gretchen Markel External Utilities Lead, Global KYC Operations, HSBC

To date, more than 4150 financial institutions: 55 Central Banks & Monetary Authorities 2,250 + in Europe, Middle East and Africa 1150 + in Asia Pacific 750 + in the Americas 200 + countries Adoption to date – to be updated frequently!!!! Point out that KYCR is a global solution with very consistent market penetration in all regions of the world. Our market share in EMEA is very similar to APAC and US Also point out that we are proud to have central banks on board. In many countries, central banks have regulatory oversight, and seeing them work with us is a strong (indirect) sign of endorsement

SWIFT Name Screening Service Single Name and Batch Screening Lists of: Politically Exposed Persons Relatives & Close Associates Sanctions Ownership Other Official Lists (e.g. FBI)* Adverse Media* * Coming Soon Your institution private lists Multiple lists each with 10,000 entities Sanctions Lists by SWIFT Monitored Validated Enriched Standardised Including: Databases Retail Customers Corporate Customers Client Databases Batch Screening *Coming Q1 2018 Delta Screening Screening Engine Single Entity Screening Case management via GUI Timeframe Time to compliance Few weeks Footprint Installation and Integration Zero Scope Formats screened SWIFT Predefined Format System performance Batch volume limitation Up to 25 million records Level 1 Level 2 Results User(s) Interface authenticated via Secure Tokens

SWIFT Compliance Services Name Screening Sanctions Screening Sanctions Testing Get support throughout the compliance and financial crime control process Transaction & customer screening Customer due diligence Customer screening Start Business Compliance Analytics Payments Data Quality RMA / RMA Plus Bankers World Online Name Screening The KYC Registry

SWIFT Sanction Screening Bank A Bank B SWIFT Network Transactions Inbound or outbound Transaction is delivered (no hit or false positive) Transaction abort notification (outbound) Transaction is delivered flagged true hit (inbound) User(s) Interface authenticated via Secure Tokens SWIFT Sanction Screening Service Case management Level 1 Level 2 Timeframe Time to compliance Few weeks Footprint Installation and Integration Zero Scope Transaction screened Fin Cat 1,2,4,7,9 System performance Volume limitation Real time unlimited

Sanctions Testing: Overview Define test objective Download test files Process test files Upload hit results View test results Formats Settings Lists Automate • Repeat • Compare • Monitor Exact match testing - evaluates the filters capabilities to match sanctioned names as they appear on the tested sanctions lists. Risk information match testing - evaluates the filters capabilities to match additional risk information such as BICs and country names. Fuzzy match testing - evaluates the filters capability to match variants of sanctioned names.

SWIFT Compliance Services Name Screening Sanctions Screening Sanctions Testing Get support throughout the compliance and financial crime control process Transaction & customer screening Customer due diligence Customer screening Start Business Behavioral monitoring Compliance Analytics Payments Data Quality RMA / RMA Plus Bankers World Online Name Screening The KYC Registry

Compliance Analytics: Overview Track RMA status evolution over time Geographic distribution of RMAs Monitor correspondent relationships RMA relationships in high-risk countries Monitor hidden payment flows & nested activity Identify countries of origin and destination, and which institutions are involved Compare relative distribution of transactions by value range Track value range evolution over time Spot anomalies in correspondent behaviour

SWIFT Compliance Services Name Screening Sanctions Screening Sanctions Testing List Management Get support throughout the compliance and financial crime control process Transaction & customer screening Customer due diligence Customer screening Start Business Behavioral monitoring Compliance Analytics Payments Data Quality RMA / RMA Plus Bankers World Online Name Screening Leveraging more than 40 years of innovation and expertise, SWIFT’s comprehensive suite of financial crime compliance products enables you to set the standard in operational insight, transparency and regulatory compliance. Ongoing due diligence The KYC Registry The KYC Registry

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