Compliance, Ethics & Sustainability Voorheen tijdschrift voor Compliance 2023 nr. 5

Sanctions Compliance Programs for the Fintech Sector

Amir Fadavi and Elizabeth Severinovskaya1

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The financial technology, or "fintech" sector has grown dramatically in recent years.2 The number of new fintechs increased by more than 70% globally between 2019 and 2020 as the COVID-19 pandemic hastened technology adoption.3  With this rapid rise in technological innovation, sanctions compliance officers are encountering novel challenges which are exacerbated both by 1) the inherent features of fintech solutions, such as reduced customer friction, seemingly borderless payments, and a reliance on a complex network of underlying financial partners; and 2) an increasingly unstable geopolitical climate that has resulted in ramped up complex sanctions and unique sanctions evasion techniques.  With this in mind, sanctions compliance officers in the fintech sector may be wondering how to develop and maintain a purpose-built sanctions compliance program tailored to their unique risk profile.  We share below some best practices for fintech sanctions compliance programs, leveraging ...

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Verder in dit artikel:

1. The Issues

2. How to address these issues

3. First Step – Management Commitment

4. Step Two – Sanctions Risk Assessment

5. Step Three – Building A Set of Internal Controls

6. Step Four – Training and Communications

7. Step Five – Testing and Audit

8. Step Six – Managing Financial Partners’ Compliance Expectations

9. Conclusion

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Artikel informatie

Amir Fadavi and Elizabeth Severinovskaya1
Ik ben auteur van dit artikel
Datum artikel
Uniek Den Hollander publicatienummer

Verder in 2023 nr.5


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