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IBank® FATCA ENFORCE
IBank® FATCA ENFORCE module is designed to assist
Banks and MFIs (designated as FFI by the USA IRS) with
their efforts in order to achieve compliance with United States
of America – Foreign Account Tax Compliances ACT. Our
deep knowledge of financial institutions KYC issues and AML
requirements allows us to properly manage and implement
FATCA solutions. Banking on our extensive expertise within
the banking environment (since 1988) and our deep knowhow
in data collection & validation, indicia analysis, transactional
screening and anomalies classification we believe that IBank®
FATCA ENFORCE
covers foreign financial institutions
(FFI) requirements by complementing their core banking
applications by introducing modular enhancements.
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IBank® FATCA ENFORCE aims at covering all aspects of
FACTCA implementation:
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Pre-existing Accounts KYC indicia analysis.
On-boarding new accounts verification & scoring.
KYC Upgrade data path.
KYC FATCA related document management.
KYC Document scanning and archiving.
“Shareholders” identification & Screening.
“Proxy” accounts screening.
“Minor” accounts screening.
FATCA “de minimis” Reporting.
Clients Due Diligence FATCA investigation.
SWIFT Remittances monitoring.
Foreign banks BIC code monitoring & reporting for
NPFFIs.
Generating FATCA/OECD v1.1 XML files.
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Turnkey Systems sarl – 2014 - Confidential
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Module Overview
MS Active Directory Integration:. User security profiles
are integrated with MS Active Directory for unified account &
groups authentication policies.
Customizable Business Process Execution Workflow
(BPEW): IBank® FATCA ENFORCE module embeds a
proprietary built in multi-level workflow process for escalation,
monitoring & follow up of accounts and transactions based on
pre-defined rules defined within the
“Business Logic
Workflow Engine” thus generating detection process results.
Suspicious transactions tagging and case follow up are
simplified. A complete historical workflow of all test cases is
stored for future reference.
Continuous investigation and monitoring on daily basis
covering new and existing accounts for any FATCA indicia
changes.
Remittances Monitoring & Withholding in Real Time.
SWIFT outgoing remittances are validated and scanned (In
both DOS PCC or RJE formats) against the clients and
correspondent records within IBank® FATCA ENFORCE
module. Recalcitrant clients and non participating FFIs
destined remittances will be withheld before being rejected or
released based on a user defined compliance workflow.
Advanced dedicated reporting engine that covers the
basic FATCA requirements in addition to that banks can create
reporting templates covering various KYC classification and
investigation requirements.
Turnkey Systems sarl – 2014 - Confidential
Design Architecture
Staging Area Building: The staging area required by
IBank® FATCA ENFORCE
module is designated for
extracting customers’ required data from Legacy Core Banking
application in order follow up, query, report and investigate
FATCA suspicious activities or follow on FATCA compliant
Accounts.
Client Based Reporting & Query: FATCA Regulatory
reporting and queries are produced based on “customer” set
criteria.
Historical Scenario Builder: The staging data area is
maintained continuously and historical data is sifted through
to assist in recognizing behavioral patterns or initiate a
cognitive scenario for FATCA investigation related Scenarios.
Turnkey Systems sarl – 2014 - Confidential
FATCA KYC
CHECKLIST
IBank® FATCA ENFORCE module is designed from
ground up to upload and complement existing KYC data
within core banking applications. IBank® FATCA
ENFORCE incorporates into the bank’s KYC the following
data for detailed indicia investigation:
v USA Nationals (Primary / Acquired nationality
/ Additional Nationality).
v Country of Birth
v Spouse Nationality.
v Green Card Holders (Permanent Resident).
v Companies registered in the USA (USA
Corporations).
v Share Holders subject to FATCA.
v Clients exceeding 180 days residency within.
USA territorial borders.
v SS/I-TIN/P-TIN/A-TIN
Number
for
Individuals.
v Employer Identification Number of Companies.
v PFFI/FFI/Compliant/Non Participating
classification for correspondent and financial
institutions.
v GIIN Management for FFIs
v USA address for FATCA compliant accounts
based on USA adopted format:
- Street number
- Street name
- Building
- Apartment number
- City
- State
- Zip code (embedded cross validation
between states and zip codes for additional
accuracy).
- Ultimate beneficiary full KYC.
- Proxy Accounts full KYC.
Turnkey Systems sarl – 2014 - Confidential
FATCA INDICIA
INVESTIGATION
IBank® FATCA ENFORCE module analyses, investigates
and scores KYC FATCA related indicia by sifting through
KYC & historical transactions. IBank® FATCA ENFORCE
clients will be screened and analyzed for possible FATCA
avoidance. IBank® FATCA ENFORCE will deploy several
user controlled scenarios for analyzing and validating existing
customer while at the same time controlling the on-boarding
process of new accounts. The investigative process covers the
following indicia:
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Original, Acquired & Additional Nationality.
USA Country of birth.
USA based residency or mailing address.
Suspicious keyword phonetic investigation in all
addresses.
USA based phone number (Mobile or Landline).
Green Card Holder.
181 day per year resident.
Ultimate beneficiary nationality.
Standing instructions covering USA outbound /
inbound remittances.
SWIFT USA outbound / inbound remittances.
Additional drill down investigative scenarios covers the
following methods are:
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Turnkey Systems sarl – 2014 - Confidential
KYC Level
v Joint account holders cross checking (if one of
the holders is subject to FATCA compliance).
v Proxy accounts (if one of the parties is subject to
FATCA compliance).
v Shareholders vs Multiple accounts cross
checking.
Transactional Level
v SWIFT RJE file analysis for clients with
Incoming/Outgoing Remittances from/to the
USA without being FATCA compliant within
the KYC.
FATCA GIIN
Management
Turnkey Systems sarl – 2014 - Confidential
IBank® FATCA ENFORCE
is designed to load
automatically
the
GIIN
(Global
Intermediary
Identification Number) list distributed by the IRS
related to compliant and participating FFIs. Based on the
IRS GIIN the SWIFT BIC Correspondent table will be
updated regarding their FATCA status. SWIFT
remittances monitoring will be based jointly on the
FATCA GIIN status and the client status. IRS GIIN list
can be updated, queried and listed from within IBank®
FATCA ENFORCE module.
IBank® FATCA ENFORCE SWIFT Monitoring allows
for SWIFT outgoing remittances to be validated in real time
flow without disrupting the normal business flow. IBank®
FATCA ENFORCE will scan all SWIFT messages and
flagging recalcitrant clients, non US clients and Non
participating FFIs. Based on a user defined compliance
workflow, SWIFT messages can be released for transmission,
cancelled or withheld amount computed and release for
transmission.
FACTA Enforce
SWIFT GENERATOR
FACTA Enforce
SWIFT Validtor
FACTA Enforce
Outgoing Remittances Monitoring
FATCA SWIFT Monitoring
Turnkey Systems sarl – 2014 - Confidential
IBANK® SWIFT Manager
FATCA Reporting
Document
Management
&
Automatic FATCA documents management is fully
maintained by the IBank® FATCA ENFORCE. Documents
printout generation for endorsement as well as document
acquisition and scanning are both fully integrated within
IBank® FATCA ENFORCE module i.e.:
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Signed IRS W9
Signed IRS W8-GEN
Signed Waiver
Passport Picture
SS Card Picture
Driver License
IRS declared reporting thresholds definition is parametric and
can be easily maintained based on IRS requirements. The
reporting levels within IBank® FATCA ENFORCE are:
reporting levels within IBank® FATCA ENFORCE are:
v Balance Reporting Thresholds.
v Gross receipt / Gross withdrawal reporting.
v FATCA declared, USA resident IRS reporting
threshold.
v FATCA declared, Non-USA resident IRS
reporting threshold.
v New FATCA compliant accounts reporting.
v Withheld accounts reporting.
v IRS reporting File generation.
Turnkey Systems sarl – 2014 - Confidential
Advanced Reporting
IBank® embeds an advanced reports processor allowing for a
highly flexible generation criteria, output criteria and output
formats. All output reports are produces in any of the following
formats:
MS Excel format (.xls).
PDF format.
Screen View format.
Physical Printout.
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Advanced reporting
functionality.
Multiple Output Formats (MS
Excel, PDF, Screen Viewing,
Physical Output)
Multiple Output Media (A3,
A4, US Fanfold)
Automated Distribution List
(via Email).
Automatic Archiving Feature.
Manual
&
Automated
production capability (via Batch
Processor).
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Turnkey Systems sarl – 2014 - Confidential
Physical output format can be any of the following:
A3
A4
US Fanfold.
Produced reports can be automated and linked to a user defined
distribution list. Reports will be generated in “PDF” format
and distributed via email.
Generated reports can be archived in PDF format and retrieved
for viewing is based on any or a combination of criteria.
BPEW
Business Process Execution Workflow:
“Business Process Execution Workflow” BPEW is
implemented throughout our AML/CTF module allowing for
thorough compliance tickets reporting, escalation, management
and closure. Our proprietary “Business Process Workflow”
engine is designed to span multi-locations. Advanced
WYSIWYG functionality workflow definition and deployment.
BPEW functionality can produce a documented printout that
can be utilized for further business process documentation.
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Business Process Execution
Workflow proprietary Engine.
User selectable criteria.
GUI Workflow Processor
Modeling.
Implemented throughout all
modules.
Unlimited Workflow Processes
definition.
Workflow Viewer
functionality (locate process
within Workflow streamline).
Documents & Reports can be
attached to workflow cycles.
Multi-Location / Multi Sites
functionality.
Turnkey Systems sarl – 2014 - Confidential
FATCA Case Management
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Cover all cases opened by the
compliance officer
Process workflow Management.
Follow up and reminders for
open cases.
Closure time limit.
Customer
Dashboard
information for quick case
resolution.
Turnkey Systems sarl – 2014 - Confidential
IBank® FATCA ENFORCE
employs an effective case
management procedure for easy investigation and reporting of
FATCA suspicious activities. By defining a “Business Process
Execution Workflow” based on case scenarios, findings will
initiate “Alerts” that are logged for investigative follow up.
In order to facilitate investigative task a widget dashboard is
automatically presented to each case officer and throughout the
workflow, comprising of current case anomaly, previous cases
history for the same customer, transactional behavioral graph
etc.
All historical case data are kept in the database for future
reference by auditors and regulatory bodies. All reports are
archived in “PDF” format for retrieval. Moreover case
workflow and reviewing process is stored in in-house
investigation of employees.
About us
The Company
TURNKEY SYSTEMS sarl is a leading software house
in Lebanon that was established in 1988. TURNKEY
SYSTEMS specializes in retail banking and large corporate
business application integration. Currently our banking,
financial & retail applications are running in various banks
and around 40 corporates. Turnkey Systems sarl currently
operates in Lebanon, Jordan and Cyprus.
Our technical staff today numbers 25 highly trained
Project manager/developers who combine higher education
with experience. In addition to the technical staff, we have a
team of six administration employees and an IT security officer.
Turnkey Systems sarl have been ISO certified since
2004. Currently our establishment is ISO 9001:2008 Quality
Management Certificated for IT Development. Currently we
are registered to obtain the ISO 17799 Certification regarding
IT Security, we expect to fulfill the certification requirements
during the second half of 2015. Our main GUI development
platform is Sybase PowerBuilder. Our Web Development is
platform is Microsoft Silverlight. Within our staff we have two
certified CITRIX administrator to insure the compatibility
between our applications and the deployment of CITRIX
environment for centralization or Web deployment.
TURNKEY SYSTEMS services falls basically into four
categories:
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Turnkey Systems sarl – 2014 - Confidential
System Integrators: Offering consultation covering
requirement studies, hardware specifications, tendering
and selection, design of organizational procedures and
workflow re-engineering.
Application Development & Implementation of turnkey
software applications.
Wide Area Network design, implementation and
commissioning.
IT outsourcing for banks and large companies.
Currently we are running 5 IT sites.
Headquarters: Beirut - Lebanon
7th & 9th Floor – Aresco Center Justinian Street - Near Central Bank
Tel : +961 (01) 352485 / 344009
+961 (03) 292905
Fax : +961 (01) 347423
Email : [email protected]
Contingency Site:
Beirut – Lebanon
Dana Bldg –Emile Eddeh Street
Office Hours: M-to-F 8:30 till 16:00 Beirut Local
Time.
Turnkey Systems sarl – 2014 - Confidential