FINTRAIL helps an international FX and payments firm to strengthen their sanctions programme
Context
FINTRAIL was engaged by a global FX and international payments firm to conduct a gap analysis of its sanctions policy and programme against APAC country-specific sanctions regulatory requirements, industry standards and best practice. The countries in scope of this review included Australia, Indonesia, Japan and Singapore.
Solution
FINTRAIL deployed a team of sanctions SMEs and regional APAC specialists to conduct an in-depth review of the firm’s sanction policy against regulatory requirements, industry standards and best practice. This comprised:
A document review of the firm’s sanctions policy, documented reporting requirements and country-specific policy addendums
A Q&A session with stakeholders to understand the firm’s sanctions programme in more detail
FINTRAIL delivered a detailed report identifying gaps and observations and provided a list of recommendations to remediate the gaps identified and enhance the current policy document in line with regulatory requirements and industry best practice.
Outcome
✓ The client received a clearly prioritised list of recommended actions that differentiated between remedial actions necessary to ensure regulatory compliance and suggestions for operational improvements
✓ The client received an in-depth assessment of its sanctions policy and programme against local regulations and expected practice to provide assurance to its key personnel and the regulators that it is operating as expected
Why FINTRAIL?
We regularly engage in sanctions compliance projects with multinational firms that require assessments across multiple business lines and widespread geographic locations within the context of different operating models, cultural and language diversity, and varying laws and business practices
Our unique team of SMEs is drawn from the industries we support and has extensive experience in leadership roles within leading global financial institutions. We understand our clients’ requirements and supply targeted, relevant assessments alongside informed recommendations and advice to produce actionable outcomes, guided by clients’ own risk appetites and decision-making frameworks
We encourage the design of nuanced, bespoke programmes based on each client’s specific offerings, customer base, and risk profiles to avoid generic solutions or tick-box compliance. We challenge conventional wisdom to identify meaningful ways to assess risk and design effective processes