Académique Documents
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Editorial Guide:
Core Content
Foreword 2
Editorial Values 3
Accuracy 3
Fit for Purpose 3
Actionability 3
Neutrality and Objectivity 3
Privacy and Data Protection 3
Core Content Scope 5
Core Content 1: Sanctions 6
What are financial sanctions? 6
Who imposes sanctions? 6
Our approach 7
Core Content 2: Regulatory Enforcement Lists 9
Core Content 3: PEPs, Businesses and State-Owned Enterprises (SOEs) 10
Politically Exposed Persons 10
Politically Exposed Businesses and Organisations 11
State-Owned Enterprises (SOEs) 11
Core Content 4: Reputational Risk Exposure 13
Content scope and definition model 13
Content acquisition model 14
Jurisdiction Priority Model 15
Revision History
Revision Date:
Revision Number: v 1.0
File Name: Core Content Editorial Guide
Author:
Modification:
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01
Foreword
This document is an overview of Acuris Risk Intelligence’s content scope, definition and acquisition model. It also outlines the core values
underpinning content creation. In this document, the term “evidence” is used in a wider sense, covering information sourced from
official, non-official and media sources. The document is an introduction to the following Acuris Risk Intelligence Policy documents:
- This new category essentially covers financial regulators and law enforcement lists
• Part 3: Acuris Risk Intelligence PEPs, SOEs and PEP-Linked Businesses Content
- This new category essentially updates the previous Adverse Media category
Please refer to these documents for a full, detailed description of each content group and corresponding editorial guidelines and research
methodologies.
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02
Editorial values
Accuracy
In a contemporary landscape dominated by fake news and widely reported non-events, Acuris Risk Intelligence is committed to acquiring
accurate and evidence-based content sourced from official, reputable non-official and selected and curated mass-media sources. Each
detail on an Acuris Risk Intelligence profile is supported by at least one source. The Acuris Risk Intelligence content team does not aim to
establish “the truth” in disputes and conflicts, or to analyse situations beyond their relevance to Political Exposed Persons (PEPs), Sanctions
and Reputational Risk Exposure as defined in this document and the editorial guidelines.
Actionability
Acuris Risk Intelligence’s ambition is to provide actionable content fully sufficient to support our customers’ due diligence and financial
crime control programmes. In this context, actionable content is defined as relevant and reliable information. To this end, our ambition is
to ensure full content coverage against the segments identified as relevant for Acuris Risk Intelligence content (i.e. PEPs, Sanctions and
Reputational Risk Exposure) as well as complete personal and corporate identifiers: full name (including alias names) in both original and
Latin script (where different), date of birth, citizenship (US) / Nationality (UK), address(es), business registration details and similar.
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Acuris Risk Intelligence Core Content Editorial Guide 4
We do not collect information concerning religious affiliation (other than as disclosed by an official title) or sexual orientation of
individuals, nor other information concerning their personal life outside the scope of our reputational risk exposure categories.
Acuris Risk Intelligence will act as a data controller in this context of profile curation and on-going maintenance and the only ‘sensitive’
personal data we collate under GDPR guidelines is that relating to relevant criminal convictions.
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03
Core content scope
Any profile of a person or entity created as part of Acuris Risk Intelligence content falls under one of the four core segments as illustrated
below:
Sanctions
• Persons and entities subject to international economic sanctions
Regulatory Enforcement
• Financial and other regulatory lists
• Law enforcement lists
• Bankruptcies, insolvencies and director disqualification lists
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• coerce a regime, or individuals within a regime, into changing their behaviour or aspects of it (‘offending behaviour ‘), by increasing the
cost on them to such an extent that they decide to cease the offending behaviour
• constrain a target by trying to deny them access to key resources needed to continue their offending behaviour, including the financing
of terrorism or nuclear proliferation
• signal disapproval of a target as a way of stigmatising and potentially isolating them, or as a way of sending broader political messages
to international or domestic constituencies
• protect the value of assets that have been misappropriated from a country, until they can be repatriated
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• HM Treasury implements UN and EU financial sanctions through its Office of Financial Sanctions Implementation (OFSI) and makes
designations under domestic programmes. OFSI is the government agency in charge of implementing financial sanctions including
targeted asset freezes and restrictions on financial services. Breaches of UK financial sanctions are criminal offences, punishable upon
conviction for up to 7 years in prison. There are both civil and criminal enforcement options to remedy breaches of financial sanctions.
Law enforcement agencies may consider prosecution for breaches of financial sanctions. The monetary penalties regime created by the
2017 Act provides an alternative to criminal prosecution for breaches of financial sanctions legislation. OFSI can impose penalties for
sanction breaches of up to £1 million or 50% of the value of the breach – whichever is higher. “In 2016, just over one hundred
suspected breaches were reported to OFSI, 95 of which were actual breaches, totalling around £75 million.”
In addition to the above-mentioned sanctions regimes, Acuris Risk Intelligence also monitors other national or unilateral sanctions which
are enforced at national level. Individuals and entities featuring on such lists may not be flagged as sanction but are identified as being on
the local sanction list. This approach enables Acuris Risk Intelligence customers to easily distinguish between those who are subjected to
international sanctions and the local ones. For example this would include the following but is not limited to:
• Australia Department of Foreign Affairs and Trade - Listed terrorist organisations
• Belgium Federal Public Service - National financial sanctions
• Canada DFAT Consolidated List of Sanctions and OSFI Designated Individuals and Entities - Terrorism Financing
• China Ministry of Public Security Terrorist List
• France Individuals Subject to Asset-freezing measures
• Japan Ministry of Finance - Economic Sanctions
• Russia – Federal Financial Monitoring Service, Unified list of terrorist organizations
• Swiss State Secretariat for Economic Affairs - Terrorism list
The list above is simply an illustration of Acuris Risk Intelligence’s sanctions coverage and not intended to provide a full disclosure of all
sources regularly monitored by Acuris Risk Intelligence. For a full list of sanction lists screened by Acuris Risk Intelligence, please contact us.
Our approach
At Acuris Risk Intelligence we regard sanctions coverage as one our most important responsibilities given that sanctions are absolute
requirements depending on the jurisdictions where our customers are based and the currencies they transact in.
Our sanctions team is manned around the clock with a dedicated team of multilingual area specialists who monitors all sanctions for new
releases daily and on a rolling round-the-clock schedule as well as being subscribed to various news and email alerts issued directly by the
sanctioning bodies. Alongside the sanctions team, analysts and senior matter experts from the content team also screen local national
sources daily as well as a wide selection of regulatory bodies and watchlists from around the globe.
A wide range of sanctions websites are crawled by spiders and relevant content captured and delivered in dedicated queues for expedient
data processing.
Our content creation and update procedures are subject to strict auditable quality assurance procedures and every effort is made to avoid
errors, missing data fields or the duplication of profiles to ensure as a provider, we are timely and accurate in our gathering and sharing of
sanctions and regulatory enforcement content.
The level of detail for profiles of individuals and entities created in Acuris Risk Intelligence under the sanctions content category may vary
depending on what information the official list provides, but it does typically include: full names (including names in local script in case of
non-Latin alphabet, such as Chinese, Arabic, Cyrillic); date or year of birth for individuals; address(es); details of the type of offence;
evidence attached as a pdf article to all profiles. Each profile does also indicate that it is “Sanctions” content.
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Our sanctions data consists not only of individuals and entities as standard but also designated vessels and aircraft and criminal and familial
organisations and associations. Within the data recorded are many searchable fields including International Maritime Organization
numbers, business registration numbers and dates, VAT numbers and aircraft model numbers and manufacture dates. All evidence is
documented within the profiles in an easily viewable pdf format and all former sanctioned profiles retained within the database as
previously sanctioned, with all evidence attached.
In terms of data acquisition, all sanction sources are screened daily and profiles created or updated promptly. The processing time for new
sanction releases varies depend on the number of names and the amount of information available for each profile; however, the
expectation is the update is completed in 30 minutes or up to 6 hours. In cases of existing sanction profiles where no new sanction data
was published, the automated review cycle is 6 months.
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This type of regulatory enforcement content is structured as a “list”, irrespective of whether the delivery format is pdf, xml, txt, html, csv or
else. The information is presented as a list of names of offenders (individuals and/or entities and their respective identification details),
subject to official regulatory enforcement action. Such content may include, but it is not limited to: fines, professional disqualifications,
licence suspensions or revocation for breaches of financial or other applicable laws and regulation, including gaming; investor warnings
related to unauthorised firms and activities; banned/de-barred firms; most wanted lists of fugitives from law, red alerts, watchlists, listings
of prosecutions and convictions etc.
Acuris Risk Intelligence’ content team consists of highly experienced, multilingual (from 3 to 10 languages) researchers who cover 240
jurisdictions in more than 40 languages, coming from either legal, media, politics and international relations, linguistics or economy and
finance background and have very good knowledge of political, financial, business and cultural affairs, including with respect to AML/CFT
legal framework. They act as the first point of contact and subject matter experts with regards to geographical area of responsibilities.
Regulatory Enforcement content is created and updated by multilingual area specialists who screen regulatory enforcement lists from
around the globe for new releases on a rolling schedule as well as being subscribed to various news and email alerts issued directly by the
sanctioning bodies.
The data acquisition model for Regulatory Enforcement Lists is aligned with the jurisdiction priority model (see section 4). The level of
ambition is that Regulatory Enforcement Lists for High Priority Jurisdictions are updated every other day, whereas for medium and low
priority jurisdictions, content creation and update ranges between three and five working days). For existing profiles where no new data
was published, the automated review cycle is aligned with the jurisdiction priority model and ranges between 9 months and 12 months. In
case of high volume data aggregated by spiders in queues as well as in cases of large amounts of data release on official websites, the time
required for updating the regulatory enforcement content in Acuris Risk Intelligence database may take longer. In such cases, special
measures (e.g. allocating additional resources on a temporary basis) are put in place to ensure that the content is being updated as soon as
possible.
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In general, the term PEP refers to a senior public official, either elected or appointed, with substantial authority over policy, operations or
the use or allocation of government-owned resources. These may include: heads of states and governments, members of legislative
assemblies; senior officials in the executive, legislative, administrative, military, or judicial branch of a government; a senior official of a
major political party; senior executive of a government-owned commercial enterprise. The scope of the Acuris Risk Intelligence PEP content
also covers immediate family members of PEPs (meaning spouse(s), parents, siblings, children, and spouse’s parents or siblings) and any
individual publicly known to be a close personal or professional associate, as well as operating companies, trusts, personal investment
companies and similar vehicles where these are publicly known to have been established for the benefit of a PEP, or a family member or
close associate of a PEP.
While such definitions are valid sources of mandate for financial institutions to consider in defining an approach to compliance with
relevant regulations, Acuris Risk Intelligence believes they are not sufficiently detailed for its clients to verify and effectively process PEPs as
this treats all PEPs equally from a risk approach is not sufficiently granular from a ‘risk-based approach’. For this reason, Acuris Risk
Intelligence has set up in-house PEP Tiering guidelines that serve as the research framework for its Acuris Risk Intelligence content team to
follow consistently throughout their research and due diligence investigations. While several categories must be treated with care in
certain contexts, the general guidelines should cover most governance systems spanning all jurisdictions in the world. In accordance with a
risk-based approach, the categories are divided into different priority levels, which also guides Acuris Risk Intelligence’s systematic data
development and maintenance procedures.
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Note: Please note that the above list of PEP roles per tier is not comprehensive and the examples provided are for Illustration purposes. For a full list of PEP
roles per tier, please refer to the “Acuris Risk Intelligence Approach to Politically Exposed Persons (PEPs), Businesses and State-Owned Enterprises (SOEs)”
The Wolfsberg Group guidance on PEPs (May 2017) clarifies, if a PEP is the beneficial owner or has requisite control of an operating
company or organisation, that person may be able to use the organisation in furtherance of corrupt purposes. For this reason, FATF
recommends that financial institutions should be required to have appropriate risk management systems in place to determine whether
the customer or the beneficial owner is a foreign PEP, or is related or connected to a foreign PEP, as well as taking reasonable measures to
establish the source of wealth and source of funds. Similarly, for domestic PEPs and international organisation PEPs, financial institutions
are recommended to take reasonable measures to determine whether such relationship exist and assess the degree of risk.
Consequently, Acuris Risk Intelligence’s approach to PEP identification and classification also maps out the relationship between PEPs and
legal entities and arrangements, either directly (as director, shareholder, or similar) or indirectly (as ultimate beneficial owner), where such
information is publicly known.
• The extent of state control over a public enterprise through full, majority, or significant minority ownership;
• The formal representation of the state on the board of directors.
For operational purposes, the following matrix guides the content creation according to the priority level assigned to each SOE:
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Acuris Risk Intelligence Core Content Editorial Guide 13
Please refer to document Core Content Editorial Guidelines – Part 4 – Reputational Risk Exposure for detailed definitions.
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The content acquisition model provides customers with an explanation of the source of the information and creates additional granularity
to support their risk models, should they require it. Ultimately this approach ensures the regulatory rationale for content is documented,
adhered to and justifiable.
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04
Jurisdiction priority model
The jurisdiction priority model is an intrinsic part of content acquisition methodology which is designed to make the most effective use of
scarce resources against the background of ever-growing body of information being released in the public domain.
The model follows a risk-based approach whereby jurisdiction matching certain risk criteria are assigned a higher priority score from the
point of view resource allocation, scope of coverage and frequency of data update. Jurisdictions that can be considered key financial
centres and economies, there more exposed to money laundering risks are assigned high priority. Similarly, countries that are subject to
economic sanctions, labelled as major money laundering hubs, sponsors of terrorism or listed by FATF under its High-Risk and Non-
Cooperative Jurisdictions programme, as well as countries assessed as having high levels of corruption by Transparency International are
also included in the high priority category.
*Please note that some jurisdictions may fall under multiple categories, e.g. some EU nations being also members of G20; North Korea (Sanctions, Sponsor
of Terrorism, FATF Non-cooperative jurisdiction), or South Africa, Argentina, Brazil, India, Indonesia (all G20 and Major Money Laundering Countries).
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