WIXLIB

[3] We need to promote public-privatepartnerships and the use of technology21Sensitivity: ConfidentialJurisdictionModelLed byCanada – Project PROTECTTypology codevelopmentPrivatesectorNetherlands – Terrorist FinancingTaskforceAnalysts colocation &typologydevelopmentProsecutorled togetherwith policeHong Kong Fraud and MoneyLaundering Intelligence TaskforceTactical infosharing linked totypologiesLawenforcementUK Joint Money LaunderingIntelligence TaskforceTactical infosharing linked totypologiesLawenforcementAustralian Fintel AllianceSecondmentbased & analystco-locationFIUUS Financial Crimes EnforcementNetworkCase briefing fortactical infosharingFinCENSingapore AML/CFT PartnershipTypology codevelopmentonlySupervisorEuropol Financial Intelligence PPPTransnationaltypologydevelopmentEuropol-led

A new perspective on the financial crimechallenge – a case study in banking instabilityABLV - one the largest banks in LatviaLatviaCountry profile: 8.1 billion in foreign deposits,controlled by 26,000 shell companies Banking system represent 40% of Latvia’sGDP! 12 February: FinCEN accused ABLV of ‘institutionalmoney laundering’– Lost access to the USD funding market– Within days there was a 600 million run-on-the-bank 19 February: ECB suspended all payments22Sensitivity: Confidential

However, that’s just the beginning wheredid the illicit proceeds go? Primary deposit flow and Czech RepublicSwitzerland Germany Switzerland Russia Secondary deposit flow destination UK Ukraine Czech Republic Estonia CyprusCyprusPrimary deposit flow23Sensitivity: ConfidentialSecondary deposit flow

Future of Financial Intelligence Sharing(FFIS) research programmeUnderstanding the role of public-private financialinformation-sharing partnerships to detect, preventand disrupt crime.www.future-fis.com24Sensitivity: Confidential

SANCTIONSCOMPLIANCEErnst PienaarHead of Content Specialists - Refinitiv

Overview: Where does Sanctions fit in World-Check data?The 5 main bucketsSanctions Coverage ofglobal sanctions 250 sanctionslists covered 100% coverageof explicitsanctions Examples:OFAC, UN,DFAT, UKHMT,CANS Keyworded Implicit(narrative)sanctionsLawEnforcement Entities andindividualswanted,investigated orarrested by anofficial lawenforcementbody Examples:Interpol, FBI,SFO, CBBI Keyworded MUICAC SITIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence Data26Sensitivity: ConfidentialRegulatoryEnforcementPEPs, RCAsand SOEs Individuals orentities againstwhom officialregulatoryadministrativeaction has beentaken World-Checkcrimes & relatedstatutoryoffenses Keyworded MUFSC MauritiusFinancialServicesCommission Coverage ofpoliticallyexposed personsto the FATF &Wolfsbergstandards Includes primaryPEPs andRelatives &Close Associates Flex to coverlocal PEPdefinitions wherethey exist State OwnedEnterprises Sub-categorizedNegativemedia Individuals orentities reliablyreported to bequestioned,charged,wanted, oraccused of aWorld-Checkcrime by a lawenforcement orregulatoryenforcementbody World-Checkcrimes

World-Check Sanctions dataModel and focusAggregates and provides clients withaccess to: Heightened risk individuals and entities From public domain data (open source)which data is: Global Intelligence Aggregated Associated Deduplicated Enhanced Structured Narrative ConsolidatedSENSITIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence Data27Sensitivity: ConfidentialGLOBALWorld-Check records individuals in every habited locationon earth – 245 countries and dependent territories – ISO3166-1

World-Check Sanctions dataAggregated and deduplicated Each record within World-Check represents only a single individual or legal entity For example, Hassan Abdullah Hersi Al-Turki (UID: 233012) is listed on 49 different government lists, but isonly listed in World-Check as a single record with 20 news articles Deduplication is a critical competitive advantage as it greatly decreases remediation efforts and simplifies matchvalidationSENSITIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence Data28Sensitivity: Confidential

World-Check Sanctions dataAggregated and deduplicated Deduplication significantly reduces the number ofrecord that need to be screened For Sanctions compliance, this can reduceworkloads by well over 000RawDeduplicatedSENSITIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence Data29Sensitivity: Confidential SanctionSets contain only the data provided by thesanction body in World-Check format with WorldCheck UIDs – transactional screening

CorporateWorld-Check Sanctions dataCorporateCorporateIntelligence and TIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence DataSensitivity: Confidential

Embargoes country transportCountry transport recordsEmbargoed (and nonembargoed) Airport AircraftSENSITIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence Data31Sensitivity: ConfidentialEmbargoed (and non-embargoed) Sea ports Vessels/ships Sanctioned/embargoed vessels Non-sanctioned vessels thatmeet World-Check inclusioncriteria

Iran relevant content [IRAN-WC]North Korea relevant content [DPRK-WC]Islamic State relevant content [ISIS-WC]All reports that are related to Iran / North Korea within World-Check are tagged with the IRAN-WC or DPRK-WCkeywords to screen against Iran and North Korea related risks and include: PEPs Listed content Risk records (organized crime, financial crime, etc.) All other records satisfying World-Check inclusion criteria All records on OFAC, UKHMT, EU and UN lists having a connection to Iran / DPRKCustomers wanting full coverage on the Iran situation may take records on IRAN-WCand IRAN-IEI keywords available with the World-Check extension/supplementarycontent in the Iran Economic Interest (IEI) specific data set. Islamic State in Iraq and the Levant/al-Sham (ISIS/ISIL), for example, those reported toISIS/ISIL leaders, members, facilitators, financiers, propagandists, foreign fighters and entitiesassociated with ISIS/ISIL.SENSITIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence Data32Sensitivity: Confidentialbe

Data quality auditsISAE3000 attestationISAE 3000 audit performed by PriceWaterhouseCoopers to check our sanctions updates forCompleteness Accuracy Validity– Sanctions content only is audited in particular:OFAC, UKHMT, EU, UN, DFAT, CANS, HKMA, SECO, MAS, MINEFI, MFAT, JMOF– Type-1 audit report (point in time)– Factors such as the following are tested:– Company controls, HR policies, etc.– IT controls– Third-party management– Disaster management, access controls, etc.SENSITIVITY: CONFIDENTIAL Refinitiv World-Check Risk Intelligence Data33Sensitivity: Confidential

NarrativeSanctionsIran and Russia case studies

Narrative SanctionsAn attempt at a definition: explicit vs. implicit sanctionsWhere a national or international “sanctions”* listing states that – Export or Trade Embargoes Financial Restrictions or Economic sanctions Asset freezes Investment bansnot only applies to the individual / entity listed (explicit sanctions) also applies to an entity not sanctioned byname or appearing on a blocked or restricted entity list but covered by a narrative statement on a sanctionsprogram extending sanctions to such non-listed entity (implicit sanctions)*e.g.35Sensitivity: Confidential

Explicit sanctions are lists36Sensitivity: Confidential

Narrative SanctionsOFAC 50% Rule – 2008/2014“Persons whose property and interests in property are blocked pursuant to an EO or regulations administeredby OFAC (blocked persons) are considered to have an interest in all property and interests in property of anentity in which such blocked persons own, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blockedpersons is itself considered to be a blocked person The property and interests in property of such an entity are blocked regardless of whether the entity itself islisted in the annex to an Executive order or otherwise placed on OFAC's list of Specially DesignatedNationals ("SDNs"). Accordingly, a U.S. person generally may not engage in any transactions with such anentity, unless authorized by OFAC.”37Sensitivity: Confidential

Narrative SanctionsOFAC 50% Rule – 2008/2014“U.S. persons are advised to act with caution when considering a transaction with a non-blocked entity in whichone or more blocked persons has a significant ownership interest that is less than 50 percent or which one or more blocked persons may control by means other than a majority ownership interest. Suchentities may be the subject of future designation or enforcement action by OFAC.”Approach? Ownership 25% (beneficial ownership) Control via voting rights or any other means Sanctioned Board Member or Senior Executive38Sensitivity: Confidential

Narrative Sanctions Enforcement ActionsOFAC 2016 / 2019 Settlement2016 Example of an OFAC settlement with an institution violating the 50% rule: Transactions with the subsidiary of a Zimbabwean SDN listed entity 159 apparent violations 2.4M fineKey takeaway:“This settlement demonstrates that an enforcement response may be particularly appropriate, even when anindividual or entity is not included on the SDN List, in response to apparent violations in which theapparent violator is an institution that maintains direct customer relationships for entities that are beneficiallyowned, directly or indirectly, 50 percent or more by one or more SDNs”2019 During this time period, the institution operated U.S. dollar accounts on behalf of the Islamic Republic ofIran Shipping Lines (IRISL) and several companies owned by or otherwise affiliated with IRISL, andmanaged the accounts of those companies in a manner that obscured the interest or involvement of IRISL intransactions sent to or through U.S. intermediaries.39Sensitivity: Confidential

Narrative SanctionsEU 50% Rule ”Owning a legal person, group or entity" means being in possession of 50% or more of the proprietary rights ofa legal person, group or entity, or having a majority interest therein. Controlling a legal person, group or entity" means any of the following:(a) having the right to appoint or remove a majority of the members of the administrative, management or supervisory body ;(b) appointed solely as a result of the exercise of one's voting rights a majority of the members of the administrative,management or supervisory bodies ;(c) controlling alone, pursuant to an agreement with other shareholders in or members of a legal person, group or entity, amajority of shareholders' or members' voting rights ;(d) having the right to exercise a dominant influence over a legal person, group or entity, pursuant to an agreement ;If any of these criteria are satisfied, it is considered that the legal person or entity is controlled by another personor entity, unless the contrary can be established on a case by case basis40Sensitivity: Confidential

Narrative SanctionsUnited Nations Resolution 1718 (2006) North Korea (DPRK)All Member States shall, in accordance with their respective legal processes, freeze immediately the funds,other financial assets and economic resources which are on their territories at the date of the adoption of thisresolution or at any time thereafter, that are owned or controlled, directly or indirectly, by the persons orentities designated by the Committee or by the Security Council as being engaged in or providing support for,including through other illicit means, DPRK’s nuclear-related, other weapons of mass destruction-related andballistic missile related programmes, or by persons or entities acting on their behalf or at their direction, andensure that any funds, financial assets or economic resources are prevented from being made available by theirnationals or by any persons or entities within their territories, to or for the benefit of such persons or entities;S/RES/2094 (2013) / S/RES/2270 (2016) / S/RES/2321 (2016) / S/RES/2371 (2017) / S/RES/2375 (2017) /S/RES/2397 (2017)10. Decides that the measures specified in paragraph 8 (d) of resolution 1718 (2006) shall apply also to theindividuals and entities listed in Annex I and II of this resolution and to any individuals or entities acting on theirbehalf or at their direction, and to entities owned or controlled by them, including through illicit means;41Sensitivity: Confidential

Narrative SanctionsOFAC Libya: 2011 (lifted)“The property and interests in property of the Government of Libya, its agencies, instrumentalities, andcontrolled entities, and the Central Bank of Libya, as well as individuals listed on an Annex to the Executiveorder, are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in pursuant to theorder.”42Sensitivity: Confidential

Narrative SanctionsUN Libya: 2011UN sanctions have implicit sanctions extensions as well.UNSCR 1970 on Libya (February 2011)“Decides that all Member States shall freeze without delay all funds, otherfinancial assets and economic resources which are on their territories,which are owned or controlled, directly or indirectly, by theindividuals or entities listed in annex II of this resolution or designatedby the Committee established pursuant to paragraph 24 below, or byindividuals or entities acting on their behalf or at their direction, or byentities owned or controlled by them”43Sensitivity: ConfidentialAnnex II (AssetFreeze)

Narrative SanctionsOFAC Syria: 2011Government of Syria (its agencies, instrumentalities, and controlled entities), and banns the importation ofpetroleum and petroleum products from the Syrian Petroleum Sector and provision of services andinvestments for and in Syria by US Persons.44Sensitivity: Confidential

Narrative SanctionsOFAC Iran: 2012The E.O. blocks all property and interests in property of the Government of Iran, the Central Bank of Iran and allIranian financial institutions (regardless of whether the financial institution is part of the Government ofIran) .Secondary sanctions introduced: Expose non-US persons to US designation risk if theyengage in nuclear-related sanctionable activity45Sensitivity: Confidential

Narrative SanctionsOFAC Iran: 2012Iran Threat Reduction and Syria Human Rights Act, August2012 (ITRSHRA): Purchasing, subscribing to, or facilitating the issuance ofsovereign debt of the Government of Iran or debt of any entityowned or controlled by the Government of Iran, includingbonds. Blocking of all property and interests in property subject to U.S.jurisdiction for officials, agents, or affiliates of the Iran’sRevolutionary Guard Corp (IRGC)46Sensitivity: Confidential

World-Check Sanctions dataIslamic Revolutionary Guard Corps – SDN47Sensitivity: Confidential

Narrative Sanctions: 50% ruleRussia OFAC / EU Sanctions – 2014 - 20182 out of 5 types of sanctions regimes instituted:Asset freezes (SDNs)Restrictions on financing (Sectoral Sanctions) – new debt / equityEU (833/2014)a legal person, entity or body whose proprietary rights are directly or indirectly owned formore than 50 % by an entity listedUS (EO 13662)Any entity owned (50% or more) by a listed personOwned in the aggregate, directly and indirectly48Sensitivity: Confidential

Narrative SanctionsOFAC Russia: April 2018Section 228 of CAATSA* amends SSIDES by inserting a mandatory sanctions provision on foreign persons Knowingly facilitate significant transactions, including deceptive or structured transactions, for or on behalf ofany person subject to U.S. Russian sanctions Their child, spouse, parent, or siblingForeign FI’s face correspondent account or payablethrough account sanctions if US determines thatthey knowingly facilitate significant financialtransactions on behalf of any Russian persondesignated as SDN* Countering America's Adversaries Through Sanctions Act49Sensitivity: Confidential

Narrative SanctionsRussia OFAC Sectoral Sanctions – 2014 - 2018Sectoral Sanctions Identifications List (the “SSI List”) - EO 13662 - Prohibited transactions by U.S.persons or within the United States transacting in, providing financing for, or otherwise dealing in new debt (bonds, loans, extensions of credit,loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper)of longer than 30/90 days maturity or new equity (stocks, share issuances, depositary receipts, or any other evidence of title or ownership) forthese persons, their property, or their interests in property.50Sensitivity: Confidential

Narrative SanctionsRussia OFAC Sectoral Sanctions – 2014 - 2018“OFAC also applies a 50 percent rule to entities on the Sectoral Sanctions Identification List (SSI List) created inJuly 2014 in the Ukraine-related sanctions context. The property and interests in property of persons on the SSIList (and entities owned 50% or more in the aggregate by one or more persons subject to the SSI List restrictions)are not required to be blocked; instead a more limited set of transaction restrictions applies to them.”51Sensitivity: Confidential

Narrative SanctionsRussia EU Sectoral Sanctions – 2014 - 2018EU No 833/2014 – 31 July 2014 - Article 5It shall be prohibited to directly or indirectly purchase, sell, provide brokering or assistance in the issuanceof, or otherwise deal with transferable securities and money-market instruments with a maturity exceeding30/90 days of: a legal person, entity or body established outside the Union whose proprietary rights are directly orindirectly owned for more than 50 % by an entity listed in Annex III;52Sensitivity: Confidential

Narrative SanctionsVenezuela OFAC Sectoral Sanctions – 2017All transactions related to, provision of financing for, a

Sensitivity: Confidential Discussion Economic crime is a massive and growing problem and pose risks for business, the public sector and citizens Public and private sectors are urged to take a public stance in this fight. Building trust and promoting collaboration is the way forward Information sharing and the use of technology are needed to