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Trade has always been the foundation of our client’s business. With over 5,800 trade specialists helping customers trade across the globe, they have access to 87% of the world's trade flows and process over US$1 million worth of trade turnover every minute. 


Doing business internationally comes with a certain amount of risk – from customer default and supplier non-performance, to currency fluctuations and varying business and cultural differences. Strict enforcement of anti-money laundering and sanctions regulations by regulators is expected to continue, with a particular emphasis on systems and controls.

Demand for financial crime professionals remains high; the most acute shortages lie within financial crime monitoring and testing, risk assessment and governance. These skills are in short supply and not readily available. 

Our client needed to review the sanctions control environment operating within its trade finance business across three different jurisdictions – one in the Far East, one in the Middle East and one in Central Europe. Whilst they had a small global team available to perform the reviews, this was insufficient for the depth and breadth of work required. 

Having worked with this client on other trade finance and sanctions projects, we are asked if we could support the review team both ‘on the ground’ in each jurisdiction and centrally from their London head office. 


Working with our client’s global team, we provided skilled resources to assist with:

  • Project management.

  • Guidance on sanctions audit methodology.

  • Training.

  • Planning and delivering key aspects of the fieldwork.

  • Quality assurance over testing and fieldwork deliverables.


We supplied a highly experienced project manager to support the client’s management team. Part of the project manager’s responsibilities included:

  • Preparing and maintaining project plans, risks registers and budgetary controls.

  • Liaising with local management in each of the three jurisdictions under review to ensure that data, systems and other logistical requirements were met.

  • Monitoring overall progress of both the controls and forensic teams and ensuring communications lines were kept at an optimal level given the restrictions of working across multiple time zones.

  • Reporting project progress to senior management and providing relevant input to written reports.


In consultation with our client, we produced a set of training materials based on our sanctions audit and forensic methodologies covering the objectives of the controls review, testing approach to be taken, documentation standards, issue logging and reporting requirements.


To supplement this formal training pack, a vital component of the review was the transfer of knowledge from our consultants to the client’s local teams via ‘on the job’ training. This knowledge transfer included:

  • Background and principles on how to perform a risk-based sanctions audit within trade finance operations.

  • Principles of conducting a forensic review including technical environments, data extraction, loading, analysis and reporting.

  • Use of specific technical software tools.


As the work was multi-jurisdictional, we were required to supply staff to each country reviewed.  The in-country teams were supported by our UK-based forensics team. Our forensics team concentrated on five keys areas:

  • Forensic tests to support our controls work.

  • Transaction & alert identification.

  • Independent alert re-decisioning.

  • KYC testing.

  • End-to-end transaction to payment life cycle.



Our client, in partnership with our staff, delivered a collated sanctions report to senior management covering several jurisdictions as part of their trade finance thematic review. Using our bespoke methodology and ‘on the job’ training, they could extend their thematic review to cover further jurisdictions.

Feedback from our client’s local teams declared that the training they had received would allow them to undertake a greater variety of financial crime work; the new skill set could now be used across anti-money laundering, bribery and corruption, as well as in the sanctions arena.

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