Anti-Money Laundering (AML)

This working group composed of over 60 high-level experts in the AML field provides a business viewpoint on anti-money laundering regulatory initiatives.

money laundering

In October 2007, the Financial Action Task Force (FATF), formally invited ICC to provide feedback on a recently issued FATF guidance paper relating
to proliferation financing and activity-based financial prohibitions
pursuant to the United Nations Security Council Resolution (UNSC) 1737.

Consequently, a Task Force on Anti-Money Laundering was created under the chairmanship of Neil Chantry, Global Head of Policy, Trade and Supply Chain, HSBC. The task force comprises 60 members, including representatives of ICC Commercial Crime Services in London.

A paper was produced and delivered to the FATF in response to their request for comments on the review of over 40 of the nine recommendations, and ICC was invited to the subsequent public consultation forums, after which more responses to the FATF review processes were made, culminating in attendance at the Consultation forum in Milan, November 2011 and the Forum in Paris in April 2012 where the rationale behind the new 40 recommendations was discussed.

The ICC delegation has raised some issues that still affect the trade finance business and is now entering into dialogue with the FATF secretariat to determine whether the related guidance notes can be modified to address these concerns.

Guidelines on sanctions clauses

The task force also produced guidelines on sanction clauses in trade-related products, including letters of credit, documentary collections and guarantees, to draw the attention of the trade finance community to the use and negative impact of sanction clauses on certain trade instruments.

With these guidelines, ICC's primary intention is to make practitioners aware of the need to be careful in their choice of counterparties or service suppliers and to emphasize that it is their responsibility to ensure that they do nothing that brings into question the irrevocable nature of the credit or guarantee, the certainty of payment, or the intent to honour obligations.

Discussion forum for trade and compliance professionals

The task force continues to act as a key review and discussion forum for trade and compliance professionals looking at the impact on trade and the mitigants that could be utilized to comply with regulation and still keep trade credit flowing and as a platform for educating practitioners about the relationship between sanctions and the ICC Rules.

Counter-Terrorist Financing / Financial Crimes Group ("CTF/FC Group")

Stemming from the AML Task Force, the BC also created the Counter-Terrorist Financing and Financial Crimes Group to handle new mandates in the area of AML, financial crimes and proliferation financing.

This group's responsibilities and work plan include:

  • Draft responses to the FATF Review of Standards/ calls for comment, a role taken on due to the response time frame requirements of the public consultation rounds.
  • Guidance to ICC Members on KYC standards, especially relating to Correspondent banks.
  • Draft a paper on the problems relating to the falsification of information on Bills of Landing to beat sanctions, either relating to vessel names etc and final destinations
  • Provide inputs to Anti-Corruption issues (in consequence of the UK Corruption Act 2010
  • Enhance collaboration with the Wolfsberg Group & FATF to ensure consistent industry positioning on these important matters.

News release on ICC guidelines on sanctions clauses in trade finance products

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