Mutual Fund State-Owned Company Scrub

A major mutual fund company was concerned that they did not have complete visibility into what extent their various mutual fund investments included state-owned companies and/or investments in industries or entities with operations that were subject to U.S. Department of Treasury restrictions as enforced by the Office of Foreign Assets Control.  The team worked with a vendor that specialized in public company data aggregation and was able to query their entire repository of publicly traded companies on each stock exchange in the world and batch process the entire list against OFAC’s various restrictive trading lists and a proprietary list of state-owned companies.   The results of this intensive batch processing exercise provided the Chief Compliance Officer with critical information about the state of the company’s OFAC and Foreign Corrupt Practices Act compliance programsand enabled him to strengthen those compliance programs based upon what was learned.