The Global Financial Crimes (GFC) group is dedicated to the implementation of Morgan Stanley’s enterprise-wide financial crime prevention efforts, which include due diligence, transactional surveillance and suspicious activity reporting as well as governance, oversight and execution of the Firm’s AML, Sanctions, Anti-Corruption and Government and Political Activities Compliance programs. Compliance with financial sanctions imposed by the U.S. and other governments and/or international organizations requires financial firms to take proactive steps to ensure that they do not engage in any direct or indirect transactions or dealings with, for, or on behalf of any sanctioned government, entity, or individual. Since 2014, even financial firms with robust, established sanctions programs have faced new challenges associated with sanctions increasingly targeting issuers of securities, including sectoral sanctions, which restrict transactions in relation to debt and equity issued by specified entities operating in particular sectors of the economy of particular countries. As a result, compliance requires preventive and detective controls with respect not only to client reference data and fund transfers but also to sales and trading.
The Capstone team will examine industry trends and benchmark the sanctions compliance space across major U.S. financial institutions, specifically examining controls with respect to sanctioned securities. The team will analyze Morgan Stanley’s sanctions compliance program and to understand its systems for wire transfers, order entry and execution, and record-keeping. The team will ultimately have the opportunity to propose programmatic solutions with which Morgan Stanley can mitigate risk in this area.