Сценарии из практики compliance-команд в банкахCompliance workflows from banks, financial institutions, and trading companies in Central Asia and beyond.
New corporate applicant. Need to screen the company, all beneficial owners, and directors against sanctions lists and PEP registry. Manual process takes hours.
| Step | Action | Result |
|---|---|---|
| 1 | Screen company name | CLEAR |
| 2 | Bulk screen 4 directors | CLEAR |
| 3 | Check UBO (2 hops) | CLEAR |
| 4 | PEP check all persons | 1 PEP L2 |
| 5 | Adverse media check | CLEAR |
| 6 | Export audit trail | CSV ✓ |
Trader plans a semiconductor shipment to Kazakhstan through a UAE intermediary. Need to check the end recipient, route, and HS codes for export control risk.
| Check | Finding | Risk |
|---|---|---|
| Intermediary | UAE entity — FATF grey list | HIGH |
| End recipient | KZ company — CLEAR | LOW |
| HS 8542 | Dual-use · ECCN 3A001 | CRITICAL |
| Destination | KZ — anti-circumvention signal | MEDIUM |
| Routing | UAE → KZ — known evasion route | HIGH |
Client submits documents for a clean-looking company. Classic shell structure risk. Who is the ultimate beneficial owner?
| Hop | Entity | Status |
|---|---|---|
| 0 | Client company (KZ) | CLEAR |
| 1 | Holding Ltd (CY) | CLEAR |
| 2 | JSC Investment Group (RU) | SANCTIONED |
| UBO | Individual (RU) — OFAC SDN | SDN LIST |
200+ corporate clients in portfolio. New sanctions designations every week. Manual re-screening is not operationally feasible.
| Date | Alert type | Entity |
|---|---|---|
| May 12 | new_listing | Watching counterparty A |
| May 08 | ownership_change | Watching counterparty B |
| Apr 29 | adverse_media | Watching counterparty C |
| 211 | CLEAR | No change detected |
Bank wants to understand if a supplier has a history of violations, fines, or adverse media before signing a contract.
| Year | Violation | Fine |
|---|---|---|
| 2014 | AML — customer identification | ₸5.7M |
| 2016 | AML — transaction monitoring | ₸4.2M |
| 2017 | Unreliable reporting | ₸1.3M |
| 2020 | Rate disclosure failure | ₸277K |
| Total | 7 violations · systemic | ₸18.5M |
KZ bank works with Russian counterparties. Need to understand secondary sanctions exposure — not just direct hits, but routing and correspondent bank risk.
| Signal | Source | Risk |
|---|---|---|
| Correspondent bank | SWIFT registry — secondary flag | HIGH |
| Route UAE→KZ | Known circumvention pattern | HIGH |
| KZ exposure index | 703 KZ-linked entities in DB | MONITOR |
| НБК actions | 86 regulatory actions — KZ banks | CONTEXT |