Working Group
Mark Gem, Clearstream
Olivier Goffard, Euroclear

In August 2015, ISSA released 17 Principles which are recommended to be implemented by the global community of securities custodians and intermediaries in order to address the critical challenges posed by financial crime, particularly where omnibus and commingled account structures are used. The Working Group also aims to foster best practice across a broad spectrum of financial crime-related risks across the industry. It is currently focused on advising members of best practice in the fields of payment transparency, sanctions screening, AML risk assessment and monitoring.

During the first half 2021, the Financial Crime Compliance Working Group is focussed on the following key topics:
  • FCC Principles Questionnaire: The questionnaire, originally published in 2017, will be reviewed and updated to ensure that it continues to meet the needs of the market. 
  • UCITS Fund Markets: The Working Group will liaise with European regulators to socialize the FCC Principles to the mutual fund industry in Luxembourg, Ireland and elsewhere with the aim of relieving uneven application of the Principles


Principles and Related Documents
  • ISSA Financial Crime Compliance Principles for Securities Custody and Settlement, second revision (05/2019)
    > PDF 326 kB
  • ISSA Financial Crime Compliance Questionnaire (ISSA DDQ), simplified version (05/2019)
    > DOC 300 kB
  • Examples of Draft Contractual Terms to Support the Implementation of the Principles (05/2019)
    > PDF 211 kB
  • Background & Overview on the Financial Crime Compliance Principles (05/2019)
    > PDF 574 kB
  • Discussion paper on Transparency in Securities Transaction and Custody Chains, issued on 22 April 2014, as pre-reading documentation for the ISSA Symposium 17.
    > PDF 360 kB

Additional documents

  • ISSA Comments to BIS's consultative document of October 21, 2015
    > PDF 414 kB
  • ISSA commissioned Study on the Benefits and Costs of Securities Accounting Systems, August 20, 2015
    > PDF 950 kB

Institutions Represented by Experts in the Working Group:

  • Banque Internationale à Luxembourg
  • BNY Mellon
  • Citibank
  • Clearstream
  • Commonwealth Bank of Australia
  • Credit Suisse
  • Deutsche Bank
  • Deutsche Börse Group
  • DTCC
  • Euroclear
  • HSBC
  • ISSA
  • Royal Bank of Canada
  • SEB
  • SIX
  • Standard Chartered Bank
  • UBS