Accenture's Philippe Guiral presents at ACAMS 14th Annual AML & Financial Crime Conference and covers critical lessons learned on recent sanctions enforcement actions.

1. Accenture Finance & Risk Services
Examining Recent
Enforcement Actions for
Critical Lessons
Applicable to Your
Institution
Philippe Guiral
September 29, 2015
ACAMS 14th Annual AML & Financial Crime Conference

2. Employee Negligence
Copyright © 2015 Accenture All rights reserved.
2
Dominant Root Causes
• Lack of knowledge of regulatory requirements, policy updates and
corresponding implications
• Lack of testing and automated controls
Recommendations
1. Executive Leadership Messaging
• Strong and Consistent “Tone at the Top”
• “Compliance Culture”
2. Enterprise Learning Capability
• Global learning program for all employees
• Role specific simulation and case-based training methods
3. Multiple lines of defense strategy
• Internal control/Global Compliance Knowledge Center
• Independent testing and audit

3. Technology Limitations
Copyright © 2015 Accenture All rights reserved.
3
Dominant Root Causes
• Interim (temporary) solutions used long term
• Source systems not configured properly
• Alerts buried in large volume of false positives
Recommendations
1. Automated robust and integrated solution
• Strategic business and technology roadmaps
• Comprehensive sanctions technology architecture
2. Ability to block customers across all source systems
• Authentication and access controls
3. Advanced technology to limit false positives
• Efficient name matching algorithms (linguistic-based translation)
• Solution able to handle volume (clustered/virtualization)

4. Data Issues
Copyright © 2015 Accenture All rights reserved.
4
Dominant Root Causes
• Issues with data quality, integrity and completeness
• Lack of Risk-based Approach
Recommendations
1. Data Sourcing Analysis and Data Quality Controls
• Integration, conformity, consistency, development and duplication
• Data integration reporting implementation
2. Integration of CDD (KYC) and Sanctions Screening
• Cannot screen what has not been included in the CDD/KYC data
collection process
3. Effective Risk-based Approach
• Delivers effective prioritization of resource activities
• Know how to screen and what to screen

5. What’s Next?
Copyright © 2015 Accenture All rights reserved.
5
Many financial institutions have conducted large scale look-back and
remediation programs relating to sanctions requirements in order to
satisfy increasing regulatory scrutiny. The good news is that
remediation programs will come to an end as Consent Orders and
enforcement actions are closed.
However, financial institutions should on an ongoing basis:
1. Assess their sanctions capabilities versus industry best
practices in order to identify strengths and weaknesses
2. Define future state improvements in order to target poor
capabilities
3. Develop a strategic roadmap in order to build and maintain a
sustainable Sanctions Program

6. Copyright © 2015 Accenture All rights reserved.
6
Visit Accenture’s Fraud & Financial Crime Blog

7. Examining Recent Enforcement Actions for Critical Lessons
Applicable to Your Institution
Copyright © 2015 Accenture All rights reserved.
7
Disclaimer
This presentation is intended for general informational purposes only and does not take into account
the reader’s specific circumstances, and may not reflect the most current developments.
Accenture disclaims, to the fullest extent permitted by applicable law, any and all liability for the
accuracy and completeness of the information in this presentation and for any acts or omissions made
based on such information. Accenture does not provide legal, regulatory, audit, or tax
advice. Readers are responsible for obtaining such advice from their own legal counsel or other
licensed professionals.
About Accenture
Accenture is a global management consulting, technology services and outsourcing company, with
more than 336,000 people serving clients in more than 120 countries. Combining unparalleled
experience, comprehensive capabilities across all industries and business functions, and extensive
research on the world’s most successful companies, Accenture collaborates with clients to help
them become high-performance businesses and governments. The company generated net revenues
of US$30.0 billion for the fiscal year ended Aug. 31, 2014. Its home page is www.accenture.com.
Accenture, its logo, and High Performance Delivered are trademarks of Accenture