ICC-Commercial Crime Services Financial Investigation Bureau FIB _________________________________________________

1. ICC-Commercial Crime ServicesFinancial Investigation Bureau (FIB)_________________________________________________ Creating an International Standard of Risk Management in Trade __________________________________________________________________ John W. Lavers � Assistant Director Financial Investigation Bureau

2. ICC-Commercial Crime Services ICC-Commercial Crime Services Current trends in Risk Management Case Examples Need for an International Operational Standard

4. ICC-Commercial Crime Services Specialised Division of the ICC Not-for Profit Organisation UN Consultative/Observer Status International Co-operation with INTERPOL Global Operations Membership-based

5. ICC-Commercial Crime Services Financial Document Analysis Financial Transaction Analysis Due Diligence Research and Analysis International Financial Crime Investigations Anti-money Laundering & Counter-terrorism Financing Financial Risk Assessment Tools Seminars, Workshops & Training

6. Current Trends in Risk Management Guidelines - FATF Recommendations - Council of Europe Voluntary Codes of Practice Standards - Basel II Principles - Wolfsberg Group on AML Initiatives & Strategies

7. Current Trends in Risk Management Directives - European Union (3rd) National Legislative Framework - Laws - Regulations - Measures

8. Current Trends in Risk Management What has been the result? - mostly government-led - overall application disjointed - continuing national limitations - increased confusion on implementation - �go it alone� attitude by some - out-right refusal by others to comply

9. Current Trends in Risk Management Direct Challenges to RM Implementation: Different Interpretation of Words - �associated� & PEP - �red flag� lists - suspicious matter / activity - method / tools of collection / verification of information

10. Current Trends in Risk Management Differences in approaching RM a) Prescriptive-based RMS or b) Performance-based RMS

11. Current Trends in Risk Management Differences in Implementation - Government Regulations & Measures - AML Policies (private sector) - Standard Operating Procedures

12. Case Example 1 A member bank contacted IMB to request assistance with an enquiry pertaining to existence of a B/L. Checks were conducted and resulted in the following:

13. From One Random Check

14. Case Example 2 Business working together against the bank Fraud at both ends of the trade and financial transaction (trade-finance fraud) �Carousel� fraud involving the same shipping container Results are as follows:

16. Case Example 3 FIB received a request from a member in Asia to perform a review of a financial contract involving over 100 documents. Given that there were some minor difficulties some of the documents, one document raised some concern from a FIB analyst.

18. International Standard for RM Need to make RM & DD/KYC Checks easier Need to have these checks done to an operational standard acceptable to the parties involved Standard needs to be recognised Requirement for international exchange of information

19. Proposal a central authority, body or committee to set standards for operational effectiveness to implement those operational standards �what we say is what we will do� this central authority, body or committee perform the task without commercial bias described as providing a conversion / converter service between different RM structures or systems

20. Benefits Common international approach to RM Assurance / confidence / trust and creditability of a global operational standard An organisation has provided for a common denominator against the process of RM, DD, & KYC Avoid regional practices, individual interpretations & local applications of RM; and Avoid inconsistency and builds sustainability

21. Thank you for your attention. John W. Lavers Assistant Director ICC- Commercial Crime Services Financial Investigation Bureau (FIB) Telephone: +44 (0)207 423 6960 E-mail: fib@icc-ccs.org Website: www.icc-ccs.org