Statement of Objectives-Banking.pdf

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Statement of Objectives-Banking Information

Purpose

FinCEN requires an online database subscription to compliment the research done revolving around Bank Secrecy Act Data and several FinCEN functions. Multiple FinCEN offices use banking information to supplement, confirm and enhance information they use for their functions.

Typically one subscription service is divided among multiple offices with varying degrees by a low number of users. Flexible access to such data is regarded as vital to our mission. For instance, one office may need to look up the history of a banks names and another may need to do more in depth research. One analyst may use it several times a month while another may use it once a year. This leads to unpredictable usage patterns and paying for access that is not needed regularly. Typical licensing strategies are not cost effective for FinCEN.

FinCEN requires data subscriptions to be reasonably priced for the usage per year. Wide access is also a requirement so that all FinCEN analysts have access to the data as needs as roles and responsibilities often change. FinCEN needs everyone to have access for their specific need when it comes up without waiting for licenses to be transferred. There is a high administration cost to transferring licenses for a single query to be conducted. There is a need to track usage for accountability and for analyzing usage patterns and predicting future needs.

Scope

FinCEN is looking to the marketplace to find banking information that can be used on site and meet the needs of each FinCEN section including Analytical, Operations, Regulatory and Enforcement, etc. The elements that were of most importance were leadership structure, ownership data, correspondence relationships, asset and liability analysis, and domestic and global branches.

Period of Performance

Jan 1, 2025-Dec 31, 2030

Background

There has been a relatively small need for banking lookup in recent years at FinCEN. FinCEN is searching for a better solution than expensive licenses that needed to be transferred between people and divisions for a query to be conducted. Ideally, FinCEN would like licenses for up to 30 regular users but with additional logins provided so licenses don’t have to be transferred constantly. FinCEN also requires usage data for determining future requirements.

Performance Objective-Requirements

Data

• Identify, verify and link entities involved in (trans)national business activities

• Bank Lookup

• Bank corporate family tree

• Bank Beneficial Ownership

• Globally comparable metrics

• You can search for banks, branches or accounts; by country, address or entity identifier

• SWIFT BIC history and over 810,000 Standing Settlement Instructions (SSIs) specifying beneficiary, clearing systems, SEPA, correspondent banks with BIC, intermediaries, account numbers and asset classes.

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• Global and domestic ultimate owners, including governments, public authorities, individuals, beneficial owners and minority shareholders, and subsidiary relationships.

• Millions of financial institutions

• information on insurance companies, savings and loans institutions, credit unions and holding companies and over 40,000 banks and bank branches – in all countries.

• global database of banks and non-bank financial institutions.

• covers banks, bank subsidiaries and affiliates, central and correspondent banks, and non-bank financial institutions. It offers you financial, payment and ownership information, as well as data on individuals associated with these financial institutions.

• Legal Entity Identifiers (LEIs)

• International Bank Account Numbers (IBANs)

• SWIFT Business Identifier Codes (BICs), including current BIC and history, and SWIFT MT094 messages advising of past and future changes to BICs

• National Clearing Codes (NCCs), linked to BICs and including American Bankers Association

(ABA) routing numbers. NCCs are routing codes for payments to an account without an IBAN

• Clearing House Interbank Payments System Universal Identifiers (CHIPS UIDs)

• GIIN, ISIN, RSSD ID and VAT/tax numbers

• Organized in a way that makes relationships between financial institutions and holding companies clear

• Timeliness of data

• ownership data and percentage of ownership

• Includes historical name changes

• Includes corporate structure

• Includes correspondent relationships

• Includes domestic/global branches

• Includes history of the banks mergers and acquisitions

• Identify global and domestic ultimate owners

• granularity, accuracy, and breadth of data returned

• A current snapshot of all Banks listing Bank A as one of their correspondent banks-Report to show the Global footprint of Subsidiaries, Foreign Branches and Correspondent Bank of the target entity. Compliant with FATF guidelines, this feature helps detect any undisclosed nested relationships of a correspondent institution's respondents. It maps the geographic exposure of an institution by linking its respondent relationships, branch network, subsidiaries, and owners above 10% with each country's associated AML risk index. Allows FINCEN analysts to identify all geographical locations in which a given bank has some form of presence or secondary correspondent banking relationships.

• Team licenses can be assigned and shared by individuals, teams or offices as required by FinCEN. Each Team License provides non-concurrent access so 1 user can use the team license at any time. If an existing user is already using the team license then they will be automatically logged off as the new team member logs on.

• Usage can be tracked and reported monthly by individual user and number of queries.

• Easy access to historical data by searching any Bank Identifier Code (BIC)

• User-friendly and interactive visualization of historical information by time, currency and asset category

• Print Report or download as PDF

Sources

• Varied and verified sources

Search Criteria

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• Robust searching

• Enter an address,

• searching for a Business Identifier Code (BIC)

• Must be searchable by financial institution name

• Must be searchable by leadership names

• Must be searchable by ownership data

• Must be searchable by correspondence relationships

• Must be searchable by location

Additional Requirements

Report to show the Global footprint of Subsidiaries, Foreign Branches and Correspondent Bank of the target entity. Compliant with FATF guidelines, this helps detect any undisclosed nested relationships of a correspondent institution's respondents. It maps the geographic exposure of an institution by linking its respondent relationships, branch network, subsidiaries, and owners above 10% with each country's associated AML risk index. Allows investigators to identify all geographical locations in which a given bank has some form of presence or secondary correspondent banking relationships.

Historical Standard Settlement Instruction (SSI) information. The tool allows users to access historical and current SSI information of a given Bank Identifier Code (BIC) by various currency and asset categories.

● Easy access to historical SSIs by searching any BIC of your choice

● User-friendly and interactive visualization of historical SSI information by time, currency and asset category

● Can be viewed online or downloaded as PDF and also printed

Results

• Verify a bank

• It is organized in a way that makes relationships between financial institutions and holding companies clear

• understand their management and corporate structure.

• nature of business

• See a bank’s corporate structure

• Quickly reconcile entities using more than 130 entity identifiers

• Investigation software that links

• Create graphs showing

• intuitive interface

• allow quick identification and navigation between company pages and information.

• detailed view of a bank by showing its detailed corporate structure

• Access payment information

• ability to follow the trail of ownership and subsidiary information.

Reports and Download of Data

• Output screens must be downloadable into pdf

• Detailed Reports

• Downloadable bulk data into excel

Services

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• Training Provided

• Incorporation of suggestions

• investigative services-Investigations team supplements our software capabilities by providing investigation resource to your own team.

Usage Reports

• Must be able to track usage by user and number of searches monthly

Operating Constraints

• There are budgetary constraints.

• Site license with individual logins or agency managed transferable licenses that is reasonable for the usage we demonstrate. Estimated Usage: Collectively 100 queries per month.

• Our need to verify references from our international law enforcement partners

• Tracking of searches by user and number of queries

• Usage must be tracked and reported monthly by user and number of queries.

Response

• The response should describe the data that the vendor provides

• FinCEN is looking to make providing access to the agency easier with a tools choice that represents the value of the data that is accessed.

• Geared toward government criminal investigations

• Geared toward bulk data searches or output.

• Global/US based

• The licensing strategy