Xiaorong Guan

Payments Escalation

• Investigate potential true matches escalated via Fircosoft, conducting thorough reviews using multiple sources including World Check, UKHMT, OFAC, internet research, SWIFT referrals, and internal Financial Crime Workflow tools
• Assess escalations against sanctions lists, identifying false positives and confirming true matches eligible under sanctioned due diligence protocols
• Apply local procedures for UAE, US, and APAC Private List escalations based on enrichment comments; liaised with regional teams when procedures were unclear or unavailable
• Perform enhanced payment reviews for transactions involving SDNs, broadly and narrowly restricted countries (e.g., Syria, Iran, North Korea, Cuba, Venezuela, Ukrainian regions), embargoed destinations, and SSI entries
• Draft and submitted enhanced payment review records to Group Policy team for approval when transactions were legally permissible and aligned with Barclays’ risk appetite
• Ensured strict compliance with OFSI, OFAC, and EU license terms; verified client attestations and confirmed consistency in business activities
• Raise Payment Exceptions for transactions outside Barclays’ risk appetite but legally permissible, providing rationale to avoid undue business disruption
• Initiate fund freeze requests for SDN-related holdings when required by jurisdictional regulations; declined non-compliant payments and advised Relationship Directors on next steps.
• Review pre-advices and notifications from Relationship teams regarding proposed payment activities involving sanctioned regions or restricted parties; provided advisory guidance on bank supportability
• Mark avoidable escalations on false alerts, provide feedbacks to operations operators.
• When there is uncertainty and ambiguity on correct interpretation of legal definition, refer to relevant legal team for further opinion.
• Respond to queries from Relationship Directors regarding client transactions and sanctions implications.
• Maintain comprehensive inventory records, ensuring all supporting documentation and annotations were accurately logged.
• Create internal Private List entries to monitor certain sanctions related activities, take ownership of updating and deleting relevant records for effective sanctions screening as well as reducing risk of over screening.
• Contact list management team when Delta list record needs updating.
• Remain current on sanctions policies, procedures, and regulatory developments across UK, EU, and OFAC frameworks

Trade Escalations

• Review trade referrals submitted via OWS, identifying potential true matches against sanctions lists
• Assess and eliminate false positives to facilitate timely trade approvals
• For transactions involving sanctioned parties, determine business’s role—whether in pre-contractual relationship or acting as correspondent bank—and made decisions aligned with sanctions restricted activity matrix. Where support was possible, ensured alignment with internal governance protocols
• Apply local procedures for trades involving U.S.-origin goods, dual-use items, or goods destined for military end-users, securing relevant risk approvals in accordance with regulatory requirements

• Conducted independent reviews of payment samples triggered by conflicting assessments between sanctions operators, delivering clear decisions and actionable feedback
• Ensure daily documentation of all communications and decisions for audit readiness and regulatory transparency.
• Produce weekly reports for senior leadership, highlighting quality control (QC) error trends, policy gaps, and opportunities for procedural enhancement.
• Design and deliver targeted training materials to support sanctions operators in achieving QC benchmarks and improving screening accuracy.
• Act as a subject matter expert on sanctions-related queries, providing guidance across teams and ensuring consistent interpretation of regulatory requirements.
• Proactively identified inefficiencies and areas for improvement, taking ownership of process enhancements to strengthen operational effectiveness and compliance outcomes.

• Conducted in-depth investigations of payment message referrals, apply risk based decisions on false matches
• liaise with relationship management team or contact retail customer to request further information on payment messages if a risk based can not be applied
• Identified deviations from standard operating procedures, understanding causes and preventing reoccurrence .
• Updating procedure manuals, work definitions and standard operating procedures by job title or work area.
• Reject payment messages that are potential true matches to sanctions listed entries
• Escalate established true matches to compliance team
• Provide training to new joiners
• Ensure up to date with all required trainings
• Assist senior management with complex and urgent queries

• Manage claims process for PPI cases ensuring adherence to regulatory guidelines.
• Investigate customer complaints meticulously to provide accurate resolutions.
• Collaborate with cross-functional teams to enhance communication and efficiency.
• Document case details systematically to maintain comprehensive records.