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ICC Financial Crime Risk & Policy Group issue 2 Policy Statements

11/06/2019

The ICC has recently issued 2 Policy Statements from the Financial Crime Risk & Policy Group.

How Does Global Trade and Receivables Finance Mitigate against Proliferation Financing?

This paper considers the application of a risk-based approach to assist Financial Institutions (FIs) in identifying high-risk customers and transactions in relation to Proliferation Finance (PF) related to Weapons of Mass Destruction (WMD). 

The paper can be found here Mitigation against Proliferation Financing.pdf

Financial Crime Compliance Checks on the Price of Goods in Trade Transactions – Are Price Checking Controls Plausible?

This paper outlines the various potential methods for checking the price of goods, and their feasibility, demonstrating that there are significant difficulties in implementing effective price checking for Trade Finance transactions:

- Price Checking, beyond a common sense check for manifestly unusual pricing, is extremely challenging for Financial Institutions to carry out when processing trade documentation.

- It is not plausible for a Financial Institution to develop a binary financial crime control for price checking and automated systems have, to date, not proved to be effective.

- Even where publically available pricing information is available (such as for commodities) price checking remains challenging due to the multiple factors which constitute the final price of the underlying commodity in a transaction

The paper can be found here Financial Crime compliance checks on price of goods.pdf


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