Has your AML system seen South Sudan yet?

In August, the International Standards Organization announced a new country. Well, a new ISO country code for a new country.

South Sudan.

The announcement detailed the new country code (SS), new currency code (SSD).

Overnight, 8.26 million people were in a new country.

Here's a checklist of things you might want to consider in your own AML, sanctions screening and compliance systems.

• Recognize the new country code. It'll start showing up on addresses, the party details on wires, information on letters of credit, currency transactions, and so on. It's a real country code, you should be able to recognize it.
• Recognize the new currency code. Again, you might start seeing it in FX transactions, in wire transfers and so on.
• Be on the lookout for new SWIFT BICs for banks operating in South Sudan. Some weeks after the ISO announcement, SWIFT will institute new BICs using the country code in positions 5 and 6, and will then migrate certain banks in the market to the new codes.
• Create a country risk rating for South Sudan. Maybe easier said than done, if you rely on third party information sources for rating data. You may have to establish an interim evaluation based on your assessment of the components of your country risk rating. (An upcoming post will show a DIY country risk-rating approach.)
• Assess the impact on your sanctions screening and OFAC processes. OFAC is going to a fair amount of trouble to exempt South Sudan from the current slate of Sudan country sanctions. (They're still a little stuck on how to craft language that will support South Sudan's oil industry. All the pipelines go through Sudan to reach the sea.) Focusing solely on the string “Sudan” will cause you to handle a lot false hits.

It's possible to turn this into a checklist that you can use every time the ISO organization formally assigns a new country code. South Sudan, the most recent, is a little more problematic than St. Bart's which was assigned a country this past December.

Yet, the key impacts will be the same;

• new country codes
• new bank Ids
• new currency codes
• new country risk assessment
• impacts on sanctions screening or proprietary list screening.