Sanctions screening model validation
Sanctions screening model validation
Are you struggling to determine if you are using the correct sanctions lists to screen your customers and transactions? Do you have any doubts that all the necessary information is being screened and that no manipulations are being performed? Do you want to know if your sanctions filter is efficient and effective?
Case study
When a new investor from the USA provided capital to our bank, and the regulatory review was scheduled within the next six months, I wanted to be sure that my sanctions screening model was compliant, reliable and up-to-date.
Having in mind the increasing regulatory scrutiny over sanctions regimes compliance, their fast-changing nature and impressive fines and reputational damages in case of non-compliance, I decided to invite PwC to run a comprehensive sanctions model validation of our bank.
I needed to ensure that:
- I was following all the required local, EU, US and international sanctions programs;
- all relevant transactions and customers were being screened;
- there were no data manipulations along the way;
- all my sanctions-related and payment/KYC systems were properly integrated and were feeding the sanctions filter with all the relevant data;
- my screening filter was effective and tuned in the best possible way;
- our policies and procedures were effective and covered all aspects of sanctions-related processes.
PwC experts provided a comprehensive assessment of all the components of the sanctions model. They tracked the path of each payment through the complex IT systems of the bank and challenged all the policies and procedures when doing job shadowing.
Additionally, PwC experts tested my sanctions screening filter using special PwC-built software and provided a complex analysis of the filter’s performance.
Having a very detailed analysis and review of all the processes connected to sanctions, I was able to focus my efforts on eliminating identified gaps and be ready for the regulatory review.
Computer forensics and eDiscovery
Computer forensics and eDiscovery
Do you suspect that your employee’s laptops and mailboxes may contain valuable information? Do you think someone is leaking your confidential data? Have you or your employees fallen victim to a phishing attack?
Case study
When my competitor introduced an almost identical copy of my product to the market a mere month after my company did, three times in a row, always just a few percentage points cheaper, I was sure someone was leaking our materials and contracts to the competitor. I had reason to suspect that some of my employees were in contact with that competitor, but how could I prove it? I really wanted to look at their computers, but my IT department explained that we needed highly specialized technical skills and equipment that we didn’t have in our organization. I also wasn’t really sure what I could and could not look at from a legal point of view.
When I reached out to PwC, their forensic experts explained the technical process and worked closely with our external counsel to ensure the investigation would not breach employment or data protection laws. After a strategy had been agreed, their technical experts went in and secured evidence from a number of laptop computers.
The PwC experts then processed, filtered and reviewed several tens of gigabytes of communication, deleted files and various other evidence found on the laptops.
Shortly afterwards, I knew which employee should be asked some very difficult and very specific questions.
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