By Adam McLaughlin, Head of Financial Crime Solutions, EMEA NICE Actimize
Many of the financial crime technology themes that dominated 2019 are expected to re-emerge as the primary focus areas for the balance of 2020, with one key difference. While 2019 might be defined as a year of talking about what should be done, 2020 will be a year of action when many of the key themes from the past few years will start to see actual development, completion and presumably the emergence of successful use cases.
What were some of the activities that lead discussions in 2019? Regulators focused more fully on advanced technologies such as how intelligent automation and advanced analytics could assist in monitoring and detecting unusual behaviour. Regulators also began more favourably accepting the integration of advanced technologies which could assist within formation sharing, helping to better detect and identify illicit movements of wealth.Additionally, financial services organisations (FSOs)began to look at how to converge fraud and AML monitoring for better oversight of unusual activity.
With greater focus on Ultimate Beneficial Ownership (UBO), we also saw FSOs bringing reformation to KYC processes in order to reduce the risk customers pose to their organizations while better understanding their customers and corporate structures.
Finally, 2019 demonstrated an increased impetus to understand and mitigate the financial crime risk posed by virtual currencies, especially given the changes brought about by FATF’s June 2019 guidance and the EU’s 5th Money Laundering Directive, which came into force across the EU on the 10th January 2020.
Based on these actions and activities, here are five key areas that will emerge from the lessons learned in 2019 – and segueing to 2020, will dramatically impact financial crime fighting and anti-money laundering activities in the year ahead.
Prediction 1 – Private-to-Private Information Sharing
Information and data sharing will dominate 2020, and we should see real information sharing solutions emerge which will allow private sector organisations to share without breaching data protection legislation. The lack of information sharing has been a major hurdle in effectively fighting money laundering, and all financial services organisations and government agencies are cognizant of this challenge. Finally, after many years of talking, we are now seeing tangible advancements in information sharing solutions.
In July 2019, the UK’s Financial Conduct Authority (FCA) ran a Tech Sprint where partnerships were able to develop and validate their solutions. 2020 will be a year in which technology solutions such as these move from pilot stages to live implementations.
The Netherlands are currently at an advanced stage in testing the viability of whether shared transaction monitoring is possible, if deemed viable, which should be determined in the first half of 2020, then this will open the door for more countries and organisations developing or buying their own solutions.
Centrally monitoring transactions across several financial institutions, or having a shared KYC utility, will give organisations much better visibility of what is normal versus abnormal, thus making it much more difficult for criminals to open accounts and move their illicit funds between different financial services organizations.
Prediction 2 – Increasing Adoption of Contextualised Financial Crime
Historically transaction monitoring, an essential element for any financial institution’s compliance program, has been a rules-based system with a set of rules and thresholds, which if triggered an alert is raised for further investigation. These types of systems are essential to regulatory compliance but have their limitations. Rules-based systems ensure obvious typologies are identified and alerts are raised. Monitoring transactions in isolation based on rules risks missing anomalous behaviour which could be suspicious. Agility in optimizing systems and contextualised monitoring are the future, and that future will gain significant traction in 2020.
There has already been much talk about converging fraud and AML monitoring, and Capital Markets and AML monitoring. 2020 will be the year we see much of this talk leading to action,with organisations converging these compliance verticals. Additionally, financial organisations need to broaden their views and analyse more data to understand the context of transactions and their customers’ activity.
Contextual monitoring will be a move away from historic norms in Financial Crime &Compliance. Siloed approaches with multiple systems working in isolation does not work when trying to detect and report suspicious activity. This year financial institutions will focus on integrating multiple internal and external data sources into a centralised, contextual monitoring and investigation tool. Providing a greater understanding of customer risk and what is normal activity for a customer across the entire organisation will allow organisations to better detect abnormal customer behaviour.
Prediction 3 – Real-time AML Monitoring
Will 2020 be the year that AML monitoring moves from batch to real time? Early indicators show that technology is moving FSOs in this direction.although 2020 may be too soon for complete adoption. Clearly FSOs are discussing the move towards real-time AML monitoring, and many are currently planning their systems and support to manage this approach in the next several years.
Aligned to this, the introduction of Contingent Reimbursement Model (CRM) in the UK will also result in a number of organizations moving to real-time inbound fraud payment monitoring. Any inbound payment which is suspicious is clearly within money laundering regulations and will need to be reported.
FSOs in other countries are also looking at moving toward real-time AML monitoring, including South Africa and Spain. While many institutions may not move all AML transaction monitoring from batch to real-time, as this would be impractical, many will take a greater risk-based approach and move some higher risk customer transactions to real-time AML monitoring. Additionally, there are operational efficiency benefits to bringing siloed AML and fraud monitoring together.
Prediction 4 – Quality not Quantity Impacts 2020
2020 will see a greater focus on fighting financial crime by placing greater importance on outcomes and providing higher quality information to the authorities as opposed to just ensuring technical compliance, a significant change for some operations.
There is more awareness of the impact financial crime has on economies, individuals and the environment. Big awareness campaigns have been run by a number of organisations in the last year, human trafficking and wildlife crime are two such campaigns. Barclays focused on applying technology to fight human trafficking, while Standard Chartered took on the illegal wildlife trade in some of its efforts.Campaigns such as these place greater focus on the effects of financial crime and greater emphasis on FSOs to conduct an effective investigation and gather sufficient information which will help the authorities recover assets and identify and stop the criminals.
Of course, complying with regulations should not be neglected, but increasingly in 2020 FSOs will focus on exceeding minimum legal and regulatory standards by adopting programs that address significant global issues. Making a real and tangible difference in fighting financial crime will continue to be a strategic direction of FSOs this year. This direction is strongly supported by the Wolfsburg Group, an association of thirteen global banks which works to address money laundering and terrorist financing efforts on a global basis.
Wolfsburg released its own detailed “Effectiveness Statement”late in 2019 said that FIs seem to be devoting a significant amount of resources to practices designed to maximise technical compliance, without necessarily optimizing the detection or deterrence of illicit activity. The organization’s recommendations included that FSOS should “establish a reasonable and risk-based set of controls to mitigate the risks of an FI being used to facilitate illicit activity.”
Prediction 5 – Greater Alignment of Standards
A challenge in fighting financial crime is the consistency of the standards adopted across different jurisdictions. Even in the EU, where 4th and 5th Money Laundering Directives have been transposed into local laws, there are differences in how the laws have been utilised. Furthermore, there are different money laundering legislation across different jurisdictions, including sentences for those found guilty of money laundering.
To better fight financial crime there must be a level playing field across the globe. This is not going to happen overnight, but Europe are taking their first steps to greater consistency. The 6th Money Laundering Directive will need to be transposed by December 2020. Some key elements of the 6th MLD are to unify predicate offences across EU member states, impose tougher sentences for money laundering offences, and to add additional offences of criminal liability for legal persons and the offence of aiding and abetting, inciting and attempting money laundering.
In 2020, the EU’s new anti-money laundering body will emerge. In December 2019, it was announced that Europe was going to set up an EU AML supervisor. Exactly what the end state of this supervisor looks like is still unclear, but it is expected that this body will enforce standards across the EU and aid in the consolidated intelligence gathered across FIU’s in the EU.
Clearly, 2020 could be a big year for meaningful inter-institution collaboration with data and information sharing taking a more central role in our fight against financial crime. Combining this focus with a more consistent and planned approach to managing our data, coupled with the impact of new legislation, will make it much harder for criminals to hide in the shadows. It will take us all working together as a collective, sharing information and aligning standards to truly fight financial crime,stop criminals and stem the illicit flow of funds.This year could be the start of a new era in how we tackle financial crime. Only time will tell if the industry adopts a stronger, results-oriented culture as it plays out its vision for the coming year.
Lockdown 2.0 – Here’s how to be the best-looking person in the virtual room
suggests “the product you’re creating is not the camera, the lens or a webcam’s clever industrial design. It’s the subject, you, which is just on e part of the entire image they see. You want that image to convey quality, not convenience.”
Technology experts at Reincubate saw an opportunity in the rise of remote-working video calls and developed the app, Camo, to improve the video quality of our webcam calls. As part of this, they consulted the digital photography expert and author, Jeff Carlson, to reveal how we can look our best online.
It’s clear by now that COVID-19 has normalised remote working, but as part of this the importance of video calls has risen exponentially. While we’re all used to seeing the more casual sides of our colleagues (t-shirt and shorts, anyone?), poor webcam quality is slightly less forgivable.
But how can we improve how we look on video? We consulted Jeff Carlson for some top tips– here is what he had to say.
- Improve the picture quality of your call
The better your camera, the higher quality your webcam calls will be. Most webcams (as well as currently being hard to get hold of and expensive), are subpar. A DSLR setup will give you the best picture, but will cost $1,500+. You can also use your iPhone’s amazing camera as a webcam, using the new app from Reincubate, Camo.
Jeff’s comments “The iPhone’s camera system features dedicated coprocessors for evaluating and adjusting the image in real time. Apple has put a tremendous amount of work into its imaging software as a way to compensate for the necessarily small camera sensors. Although it all works in service of creating stills and video, you get the same benefits when using the iPhone as a webcam.”
Aidan Fitzpatrick, CEO of Reincubate explains why the team created Camo, “Earlier this year our team moved to working remotely, and in video calls everyone looked pretty bad, irrespective of whether they were on built-in Mac webcams or third-party ones. Thus began my journey to build Camo: an iPhone has one of the world’s best cameras in it, so could we make it work as a webcam? Category-leading webcams are noticeably worse than an iPhone 7. This makes sense: six weeks of Apple’s R&D spend tops Logitech’s annual gross revenue.”
- Place your camera at eye level
A video call will never quite be the same as a face-to-face conversation, but bringing your camera up to eye level is a good place to start. That can involve putting your laptop on a stand or pile of books, mounting a webcam to the top of your display screen, or even using a tripod to get the perfect position.
Jeff points out, “If the camera is looking down on you, you’ll appear minimized in the frame; if it’s looking up, you’re inviting people to focus on your chin, neck, or nostrils. Most important, positioning the camera off your eye level is a distraction. Look them in the eye, even if they’re miles or continents away.”
Low camera placement from a MacBook
- Make the most of natural lighting
Be aware of the lighting in the room and move yourself to face natural lighting if you can. Positioning the camera so any natural light is behind you takes the light away from your face, which can make it harder to see and read expressions on a call.
Jeff Carlson’s top tip: “If the light from outside is too harsh, diffuse it and create softer shadows by tacking up a white sheet or a stand-alone diffuser over the window.”
Backlit against a window Facing natural light
- Use supplementary lighting like ring lights
The downside to natural lighting is that you’re at the mercy of the elements: if it’s too bright you’ll have the sun in your eyes, if it’s too dark you won’t be well lit.
Jeff recommends adding supplementary lighting if you’re looking to really enhance your video calls. After all, it looks like remote working will be carrying on for quite some time.
“The light can be just as easy as a household or inexpensive work light. Angle the light so it’s bouncing off a wall or the ceiling, depending on your work area, which, again, diffuses the light and makes it more flattering.
Or, for a little money, use a softbox or a shoot-through umbrella with daylight bulbs (5500K temperature), or if space is tight, LED panels. Larger lights are better for distributing illumination– don’t be afraid to get them in close to you. Placement depends on the look you’re going after; start by positioning one at a 45-degree angle in front and to the side of you, which lights most of your face while retaining nice shadow detail.”
In some cases, a ring light may work best. LEDs are arranged in a circle, with space in the middle to put the camera’s lens and get direct illumination from the direction of the camera.
- Centre yourself in the frame
Make sure you’re getting the right angle and that you’re using the frame effectively.
“You should aim for people to see your head and part of your torso, not all the space between your hair and the ceiling. Leave a little space above your head so it’s not cut off, but not enough that someone’s eyes are going to drift there.”
- Be mindful of your backdrop
It’s not always easy to get the quiet space needed for video calls when working from home, but try as best you can to remove anything too distracting from your background.
“Get rid of clutter or anything that’s distracting or unprofessional, because you can bet that will be the second thing the viewers notice after they see you. (The Twitter account @RateMySkypeRoom is an amusing ongoing commentary on the environments people on television are connecting from.)”
A busy background as seen by a webcam
- Make the most of virtual backgrounds
If you’re really struggling with finding a background that looks professional, try using a virtual background.
Jeff suggests: “Some apps can identify your presence in the scene and create a live mask that enables you to use an entirely different image to cover the background. While it’s a fun feature, the quality of the masking is still rudimentary, even with a green screen background that makes this sort of keying more accurate.”
- Be aware of your audio settings
Our laptop webcams, cameras, and mobile phones all include microphones, but if it’s at all possible, use a separate microphone instead.
“That can be an inexpensive lavalier mic, a USB microphone, or a set of iPhone earbuds. You can also get wireless lavalier models if you’re moving around during a call, such as presenting at a whiteboard in the camera’s field of view.
The idea is to get the microphone closer to your mouth so it’s recording what you say, not other sounds or echoes in the room. If you type during meetings, mount the mic on an arm instead of resting it on the same surface as your keyboard.”
- Be wary of video app add-ons
Video apps like Zoom include a ‘Touch up your appearance’ option in the Video settings. This applies a skin-smoothing filter to your face, but more often than not, the end result looks artificially blurry instead of smooth.
“Zoom also includes settings for suppressing persistent and intermittent background noise, and echo cancellation. They’re all set to Auto by default, but you can choose how aggressive or not the feature is.”
- Be the best looking person in the virtual room
What’s important to remember about video calls at this point in time is that most people are new to what is, really, personal broadcasting. That means you can easily get an edge, just by adopting a few suggestions in this article. When your video and audio quality improves, people will take notice.
Bringing finance into the 21st Century – How COVID and collaboration are catalysing digital transformation
By Keith Phillips, CEO of TISATech
If just six or seven months ago someone had told you that in a matter of weeks people around the world would be locked down in their homes, trying to navigate modern work systems from a prehistoric laptop, bickering with family over who’s hogging the Wi-Fi, migrating online to manage all financial services digitally, all while washing their hands every five minutes in fear of a global pandemic… You’d think they had lost their mind. But this very quickly became the reality for huge swathes of the world and we’re about to go through that all over again as the UK government has asked that those who can work from home should.
Unsurprisingly, statistics show that lockdown restrictions introduced by the UK government in March, led to a sharp increase in people adopting digital services. Banks encouraged its customers to log onto online banking, as they limited (and eventually halted) services at branches. This forced many customers online as their primary means of managing personal finances for the first time.
If anyone had doubts before, the Covid-19 pandemic proved to us the importance of well-functioning, effective digital financial services platforms, for both financial institutions and the people using them.
But with this sudden mass online migration, it’s become clear that traditional banks have struggled to keep up with servicing clients virtually. Legacy banking systems have always stilted the digitisation of financial services, but the pandemic thrust this issue into the limelight. Fintech firms, which focus intently on digital and mobile services, knew it was only a matter of time before financial institutions’ reliance was to increase at an unprecedented rate.
For years, fintechs have been called upon by traditional players to find solutions to problems borne from those clunky legacy systems, like manual completion of account changes and money transfers. Now it is the demand for these services to be online coupled with the need for financial services firms to cut costs, since Covid-19 hit the economy.
Covid-19 has catalysed the urgent need to bring digital transformation to a wider pool of financial services businesses. Customers now have even higher expectations of larger institutions, demanding that they keep up with what the younger and more nimble challengers have to offer. Industry leaders realise that they must transform their businesses as soon as possible, by streamlining and digitising operations to compete and, ultimately, improve services for their customers.
The race for digital acceleration began far before the recent pandemic – in fact, following the 2008 financial crisis is likely more accurate. Since the credit crunch, there has been a wave of new fintech firms, full of young, bright techies looking to be the next big thing. Fintechs have marketed themselves hard at big conferences and expos or by hosting ‘hackathons’, trying to prove themselves as the fastest, most innovative or the most vital to the future of the industry.
However, even during this period where accelerating innovation in online financial services and legacy systems is crucial, the conditions brought about by the pandemic have not been conducive to this much-needed transformation.
The second issue, which again was clear far before the pandemic, is that fact that no matter how nimble or clever the fintechs’ solutions are, it is still hard to implement the solutions seamlessly, as the sector is highly fragmented with banks using extremely outdated systems populated with vast amounts of data.
With the significance of the pandemic becoming more and more clear, and the need for better digital products and services becoming more crucial to financial services firms and consumers by the day, the industry has finally come together to provide a solution.
The TISAtech project was launched last month by The Investing and Saving Alliance (TISA), a membership organisation in the UK with more than 200 leading financial institutions as members. TISA asked The Disruption House, a specialist benchmarking and data analytics business, to create a clearing house platform for the industry to help it more effectively integrate new financial technology. The project aims to enhance products and services while reducing friction and ultimately lowering costs which are passed on to the customers.
With nearly 4,000 fintechs from around the world participating, it will be the world’s largest marketplace dedicated to Open Finance, Savings, and Investment.
Not only will it provide a ‘matchmaking’ service between financial institutions an fintechs, it will also host a sandbox environment. Financial institutions can pose real problems with real data and the fintechs are given the space to race to the bottom – to find the most constructive, cost-effective solution.
Yes, there are other marketplaces, but they all seem to struggle to achieve a return on investment. There is a genuine need for the ‘Trivago’ of financial technology – a one stop shop, run by an independent body, which can do more than just matchmaking. It needs to go above and beyond to encompass the sandboxing, assessments, profiling of fintechs to separate the wheat from the chaff, and provide a space for true collaboration.
The pandemic has taught us that we are more effective if we work together. We need mass support and collaboration to find solutions to problems. Businesses and industries are no different. If fintechs and financial institutions can work together, there is a real chance that we can start to lessen the economic hit for many businesses and consumers by lowering costs and streamlining better services and products. And even if it is just making it that little bit easier to manage personal finances from home when fighting with your children for the Wi-Fi, we are making a difference.
What to Know Before You Expand Across Borders
By Sean King, Director of International Tax at McGuire Sponsel
The American retail giant, Target Corporation, has a market cap of $64 billion and access to seemingly limitless resources and advisors. So, when the company engaged in its first global expansion, how could anything possibly go wrong?
Less than two years after opening its first Canadian store in 2013, Target shut down all133 Canadian locations and terminated more than 17,000 Canadian employees.
Expansion of an operation to another country can create unique challenges that may impact the financial viability of the entire enterprise. If Target Corporation can colossally fail in its expansion to Canada, how might Mom ‘N’ Pop LLC fare when expanding into Switzerland, Singapore, or Australia?
Successful global expansion requires an understanding of multilayered taxes, regulatory hurdles, employment laws, and cultural nuances. Fortunately, with the right guidance, global expansion can be both possible and profitable for businesses of any size.
Any company with global ambitions must first consider whether the company’s expansion outside of the U.S. will give rise to a taxable presence in the local country. In the cross-border context, a “permanent establishment” can be created in a local country when the enterprise reaches a certain level of activity, which is problematic because it exposes the U.S. multinational to taxation in the foreign country.
Foreign entity incorporation
To avoid permanent establishment risk, many U.S. multinationals choose to operate overseas through a formal corporate subsidiary, which reduces the company’s foreign income tax exposure, though it may result in an additional level of foreign income tax on the subsidiary’s earnings. In most jurisdictions, multinationals can operate their business in the foreign country as a branch, a pass through (e.g., partnership,) or a corporation.
As a branch, the U.S. multinational does not create a subsidiary in the foreign country. It holds assets, employees, and bank accounts under its own name. With a pass through, the U.S. multinational creates a separate entity in the foreign country that is treated as a partnership under the tax law of the foreign country but not necessarily as a partnership under U.S. tax law.
U.S. multinationals can also create corporate subsidiaries in the foreign country treated as corporations under the tax law of both the foreign country and the U.S., with possibly two levels of income taxation in the foreign country plus U.S. income taxation of earnings repatriated to the U.S. as dividends.
Under U.S. entity classification rules, certain types of entities can “check the box” to elect their classification to be taxed as a corporation with two levels of tax, a partnership with pass-through taxation, or even be disregarded for U.S. federal income tax purposes. The check the box election allows U.S. multinationals to engage in more effective global tax planning.
Toll charges, transfer pricing and treaties
When establishing a foreign corporate subsidiary, the U.S. multinational will likely need to transfer certain assets to the new entity to make it fully operational. However, in many cases, the U.S. multinational cannot perform the transfer without recognizing taxable income. In the international context, the IRS imposes certain outbound “toll charges” on the transfer of appreciated property to a foreign entity, which are usually provided for in IRC Section 367 and subject to various exceptions and nuances.
Instead, the U.S. multinational may prefer to license intellectual property to the foreign subsidiary for a fee rather than transfer the property outright. However, licensing requires the company and foreign subsidiary to adhere to transfer pricing rules, as dictated by IRC Section 482. The U.S. multinational and the foreign subsidiary must interact in an arms-length manner regarding pricing and economic terms. Furthermore, any such arrangement may attract withholding taxes when royalties are paid across a border.
Are you GILTI?
Certain U.S. multinationals opt to focus on deferring the income recognition at the U.S. level. In doing so, they simply leave overseas profits overseas and delay repatriating any of the earnings to the U.S.
Despite the general merits of this form of planning, U.S. multinationals will be subject to certain IRS anti-deferral mechanisms, commonly known as “Subpart F” and GILTI. Essentially, U.S. shareholders of certain foreign corporations are forced to recognize their pro rata share of certain types of income generated by these foreign entities at the time the income is earned instead of waiting until the foreign entity formally repatriates the income to the U.S.
The end goal
Essentially, all effective international tax planning boils down to treasury management. Effective and early tax planning can properly allow a company to better achieve its initial goal: profitability.
If global expansion is on the horizon for your company, consult a licensed professional for advice concerning your specific situation.
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