Compliance Due Diligence in Global Trade: Transaction and Correspondent Banking in Switzerland

"We make sure our clients stay out of the wrong headlines".

Undue diligence on counter-parties can expose a company to lawsuits, regulatory fines and may entail legal proceedings against senior management.

Bad governance and corporate malpractice can lead to criticism from NGOs and erode a brand’s integrity.

We specialize in enhanced trade due diligence (EDD) in Switzerland and ensure Swiss commodity traders and their banks make informed decisions when structuring their business and on-boarding new suppliers and clients:

• AML risks: financial crime and anti-money laundering checks, global coverage of PEPs, their relatives, close associates, related companies
• Sanctions risks: global sanctions, bribery, corruption and crime screening, consultations on Swiss sanctions issued by SECO (here)
• Reputational risks: close coverage of adverse media exposure across multiple research languages, cross-validation and determination of source reliability
• Source of wealth / source of funds: information gathering through business intelligence sources, plausibility checks identifying beneficial owners, key management, operating and litigation history

Counter-party Vetting

Information We Collect on Our Customer

• Corporate website or public media presence, number of employees
• Description of principal business activities including types of goods / services that are offered
• Principal countries of business operations
• Characterization of all incoming and outgoing transfers: approximate (i) number (ii) size and (iii) purpose of monthly transactions
• Latest financial statements
• Details of external auditor (if applicable)
• Industry associations (if applicable)

Information we Collect on Our Customer’s Customers (KYCC)

• Company background: address, website, foundation documents, description of principal business activities and countries of operations
• Company ownership: Organization chart of holding structure up to the UBOs (> 10% stake)
• Company management: list of all signatories and persons with significant control
• Additional information on external auditor, membership in industry associations, code of conduct, anti-corruption guidelines etc.

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References

Michael Bazzell (2021) Open Source Intelligence Techniques: Resources for Searching and Analyzing Online Information (independently published) (here)

FATF - Egmont Group (2020) Trade-Based Money Laundering: Risk Indicators (here)

IMF (2016) The Withdrawal of Correspondent Banking Relationships: A Case for Policy Action (here)

Nihad Hassan (2018) Open Source Intelligence Methods and Tools: A Practical Guide to Online Intelligence (Apress) (here)

Rita Piko, Laurenz Uhl, Sara Licci (Hrsg.) (2022) Handbuch Corporate Compliance (here)

WorldECR (2023) Dual-Use Export Controls in Europe (here)

WorldECR (2022) Towards a Deeper Understanding: Next Levels in US Export Controls (here)

WorldECR (2018) Dual-use export controls in international transit and transhipment (here)

The Wolfsberg Group (2022) Wolfsberg Principles for Using Artificial Intelligence and Machine Learning in Financial Crime Compliance (here)

The Wolfsberg Group (2022) Wolfsberg Financial Crime Principles for Correspondent Banking (here)

The Wolfsberg Group (2022) Transaction Monitoring Request for Information (RFI) Best Practice Guidance (here)

The Wolfsberg Group (2022) The Wolfsberg Group Frequently Asked Questions (FAQs) on Negative News Screening (here)

The Wolfsberg Group (2022) The Wolfsberg Group Frequently Asked Questions (FAQs) Source of Wealth and Source of Funds (Private Banking / Wealth Management) (here)

The Wolfsberg Group (2022) Wolfsberg Country Risk Frequently Asked Questions (FAQs) (here)

The Wolfsberg Group (2019) Wolfsberg Guidance on Customer Tax Evasion (here)

Wolfsberg Group, International Chamber of Commerce (ICC) and BAFT (2019) Trade Finance Principles (here)

The Wolfsberg Group (2019) Wolfsberg Guidance on Sanctions Screening (here)

The Wolfsberg Group (2017) Wolfsberg Group Payment Transparency Standards (here)

The Wolfsberg Group (2017) Wolfsberg Guidance on Politically Exposed Persons (PEPs) (here)