Working Group
Mark Gem, Clearstream
Olivier Goffard, Euroclear
Yannick Cherel, Standard Chartered Bank

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 has focused on supporting member firms and the wider market in achieving compliance with the Principles. ISSA does not monitor member firms’ compliance practices. Nonetheless, evidence suggests that the Principles are increasingly applied by larger and smaller securities services firms alike. 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.

To support the community of ISSA member firms, the Working Group has , published a wide set of materials which are available under Reports. The Working Group will continue its efforts to ensure strong and continuous communication to the industry.

  • March 2020: Develop draft Sanctions Screening Best Practice Guidelines for publication
  • March 2020: Develop draft Payment and Cash Transfer Best Practice Guidelines for publication
  • March 2020: Review initial Draft of a mapping of FATF Risk Indicators to the product sets offered by Securities Services firms and related mitigation guidance
  • March 2020: Next FCCP Working Group Bulletin
  • 2020: Recurrent review of the 17 Principles to be initiated


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
  • BNP Paribas Securities Services
  • 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