Martín Gil Strategy & IntelligenceMARTÍN GIL STRATEGY & INTELLIGENCE
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Financial Crime & Payments

Banking & Transaction Compliance

Bank participation and a SWIFT message do not replace verification of the underlying transaction.

A payment is a chain of controls

  1. ORIGINATOR
  2. ORDERING BANK
  3. CORRESPONDENT BANK
  4. SCREENING SYSTEMS
  5. BENEFICIARY BANK
  6. BENEFICIARY

Different banks and functions may make independent decisions based on their legal obligations and risk appetite.

Functions that may intervene

1

AML

The exact role depends on the institution, product and transaction.

2

Financial Crime

The exact role depends on the institution, product and transaction.

3

Sanctions

The exact role depends on the institution, product and transaction.

4

Fraud

The exact role depends on the institution, product and transaction.

5

Transaction Monitoring

The exact role depends on the institution, product and transaction.

6

Trade Finance

The exact role depends on the institution, product and transaction.

7

Legal

The exact role depends on the institution, product and transaction.

8

Regulatory

The exact role depends on the institution, product and transaction.

9

Correspondent Banking

The exact role depends on the institution, product and transaction.

10

Enhanced Due Diligence

The exact role depends on the institution, product and transaction.

Documentary logic

  • KYC / KYB / UBO / PEP
  • SoF / SoW
  • SWIFT — MT103 / MT799 / UETR
  • Underlying contract, invoice, title and economic purpose.
  • Sanctions and trade-finance documentation.