Create a summary to be detail with the managment with polished language from the below discussion with ANZ

Dinesh Anand - Chief
• Responsible for policy and strategy on sanctions
• MLRO officers use the trees
• Fairly standardised policy
• Use decision trees for more complex
• Melbourne
Kylie Oliver
• Works with Dinesh
• Life blood are the decision trees
• Is it a policy concern or a regulatory concern
• Try to cover all 30 jurisdictions
• Melbourne
Evelyn Kegge
• NZ
• In the policy team
Harry Solankis
• Recently joined the sanctions team (4 months)
• Responsible for the operations
• Operational risk and compliance (AML)

Carla Lewis
Monil Gupta

CURRENT PDFs

Before we turn to the new assessments, it would be great to understand how you use the current pdfs as that will obviously have a bearing on the suitability of the new assessments. I’d be grateful if you could share a few details with me in terms of:
• Who uses the pdfs?
o Evelyn
o Every decisions tree sent is archived and retained
• When do you use them?
• How often do you use them?
o Once a day - could be multiple trees for a single transaction
o Have a standardised policy that covers all the jurisdictions
• If some jurisdictions triggered - e.g. US doesn’t allow then don’t progress with it.
o Published on internal collaboration type site but with restricted access.
• Restricted access to the policy team (e.g. if there is a policy different to use).
• Used as it moves up the escalation team
 Want 25,000 people across the world to have a simple system so don’t want everyone using the decision trees
o Powerful in the right or the wrong hands - people look at them and make a determination.
o Used for people

• Where do they go once completed?
o Attach them as evidence of the assessment - to their screening system
o Use them if the team has sought an exemption and they
o Also retained within a restricted shared folder within the policy team - version numbers very important

• How long does it take to complete a pdf?
o Worst case scenario - 30 minutes
• Which trees do you use the most?
o Often multiple jurisdictions involved - will complete decision trees for all of them.
o US was the primary regulator but circumstances have now changed.
• Feedback
o Flicking back and forth between the defined terms.
o Trees are intuitive, defined and logical.
o Links to the definitions - really helpful to make certain that when certain then your doing so on the basis of the actual rule rather than what you think - links to underlying regulations.
o Useful in the current format to see what the alternative options could have been.
• If you wiped out the other options and just ended up with the final assessment.
• Wouldn’t want to add this as an additional capability - more time

Are there any particular frustrations with the current pdfs?

DEMO

USE UK DECISION TREE

Things to note:
• Based on an old version of the decision trees so there may be some differences to what you are used to.
• Transaction name
o Transaction reference number
• Defined terms glossary
• One-strike and you’re out
• Threshold questions
• Assessment summary at the end

FEEDBACK

Questions:
• First impressions?
o Dinesh - if someone else is looking at it - it would be helpful
• Unless you have the whole picture in front of you.
• On the full version - would there
• Shouldn’t have to see two documents to get the full view on this -
• It would be very helpful if the whole decision tree is available, marked up by the first person - need that option.
• It would be great to see the change itself - ideally see the tree in its entirely.
 Present the condensed version and then be able to blow it up.
o Evelyn - often reviewing a payment exemption from point of the view of a policy
• As part of the review they will look at what they could have said
o Kylie
• Need to see all of the assessment
o Harry
• Version numbers and completion date/time
• One-strike and you’re out - can we assume that this is sufficient? Don’t need to complete the whole assessment?
o If multiple points then would want to know
• Assessment summary at the end suitable to your way of working and recording requirements?
• Assuming the price is comparable to the subscriptions you currently pay, is this something you would be interested in?
o This is easier.
o Useful to have a functionality - once you select the decision tree you want you can print out and scribble on it before you go and do it in the tool.
o Imagine there are a few people who print them out and have it in physical form to go through it.

Questions from ANZ:
• Need to know which decision tree to complete.
• Some transactions are in the grey space.
• Kylie - would like to go back and re-complete the decision tree to see what the rules would have been - historical review
o Would like to say 10 days but there are things coming back 3 months / 5 months down the line.
o Dinesh - 12 months.
o Minimum record keeping period - 7 years (in some jurisdictions 10 years).