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Achieving Sustainable Economic Reforms in Greece in 2011 and Beyond




Bob Traa, Senior Resident Representative in Athens, International Monetary Fund
Ladies and gentlemen, thank you for inviting me to speak with you today, with a special word of gratitude to the organizers. I am pleased to share some thoughts on economic developments in Greece and prospects for the banking system.
More precisely, I will touch upon three items: (i) where is economy policy today? (ii) the need to reinvigorate policy momentum, and (iii) what is the task for banks?

A. Where is economic policy today?
Greece has come to a critical point. The country faces an important choice between continuing with the bold reform program to build a modern and competitive economy that provides growth and jobs; or, in the face of the difficult head winds, to allow the pace of reform to slow. We believe that would be a mistake, because it would prolong the difficult times, rather than help resolve them.
Please recall that just over a year ago the economy was in dire straits, sinking into a deep recession and facing acute fiscal and external pressures. It was against this background that the economic reform program was begun and I will argue that this bold effort has had a positive impact, contrary to the perception in some quarters that advancements under the program have been insignificant.

Let me highlight some examples:

  • The fiscal deficit. The deficit was cut by 5 percent of GDP despite a recession of 4½ percent of GDP—this is a major achievement;
  • Inflation remains too high in the headline but it is declining. Indeed, net of temporary tax effects, it has been running well below the euro-average since July 2010;
  • Competitiveness is improving, with unit labor costs falling significantly;
  • Dynamic adjustment. The structure of the economy is changing with net exports now leading growth, thereby beginning to offset the moderation in domestic demand;
  • The banking system. Very germane to today’s topic, banks have been resilient and maintained adequate capitalization (with several large banks going to the market);

In addition, the country has also started an ambitious agenda of broader structural reforms:

  • A major pension reform—one of the boldest in Europe—has materially strengthened solvency;
  • Labor market reforms have made a step forward toward greater flexibility by cutting hiring and firing costs, and allowing firm-level employment contracts;
  • Service sector reforms have begun to free up transport and restricted professions, while business environment reforms are simplifying start-up and licensing procedures, and approval processes for large investments.

In short, the country has had significant accomplishments in 2010 for which, also in comparison with other crisis countries that I have been involved with, it deserves credit.
Regrettably, however, the task of continuing these achievements has been made more difficult by stiff headwinds from a worsening domestic and external political environment:
• First, after a period of improving confidence in the third quarter of 2010, market turmoil elsewhere in the Euro area put renewed pressure on Greek spreads,
• Second, wavering political support for the program and domestic infighting, combined with mixed messages from Euro area partners, has increased uncertainty.
• Third, recurrent discussions of private sector involvement have raised market fears that undermined the credibility of Greece’s commitment not to restructure the debt.
• And fourth, the ratings of the sovereign, the banks, and their structured financing products have been downgraded, complicating liquidity management.
In this context, since the end of 2010 the implementation of the reform process has lost momentum, now placing the government’s program at a crossroads:
The structural fiscal reforms have been slow to show yields, and as a result the reduction of the fiscal deficit has had to include significant temporary fixes (such as cash expenditure compression (with arrears) and one-off measures). Without deepening these structural fiscal reforms, however, the deficit could get stuck at 10 percent of GDP going forward.
In addition, implementation of the broader real economy structural reforms has also slowed down in 2011. This means that adjustment is increasingly coming from pressure of the recession on unemployment, rather than through productivity gains and a well-lubricated reallocation of resources in the economy. Our concern is that without implementing further reforms, the economy will rebalance through lower incomes and living standards (i.e. lower demand), rather than through higher productivity and output (i.e. higher supply).

B. The need to reinvigorate policy momentum
For these reasons, it is of paramount importance to reinvigorate reform efforts and unlock economic growth potential. Making progress will require implementing reforms in four key areas:

  • First, the authorities’ medium-term fiscal strategy and the legislation necessary to implement its measures need to be approved by parliament. This strategy aims to reduce the deficit to below 3 percent of GDP by 2014, thereby putting the debt ratio on a downward path, while ensuring a fair sharing of the adjustment burden. The focus is on consolidating state entities, tax policy, public administration reform, and better targeting of social spending.
  • Second, the privatization plan also needs to be approved by parliament, and the process of asset sales should begin without delay. No-one can accuse Greece of being half-hearted if the country achieves its privatization targets through 2015
  • Third, in the area of fiscal institutional reforms, the anti-tax evasion plans need to yield results, and spending controls and fiscal reporting needs to be fully implemented.
  • Fourth, implementation of the broader real economy structural reforms to improve the business environment and employment needs to be pursued with renewed vigor. Examples include: (1) collective bargaining reforms and subminimum wage possibilities need a further push; (2) the “fast track” investment procedure finally needs to live up to its name and be broadened to additional investment projects, not just selected big ones; (3) slow phasing-in of liberalization of regulated professions or truckers reforms, needs to be avoided in future—reforms need to become effective immediately. There is a host of other reforms that have been started but where their potential has not been exhausted by any means—these also need a new dose of energy and effectiveness.

Pursuing these reforms will open up opportunities for investment and underpin greater confidence. We believe that the Greek adjustment program can be successful, and this success will also hinge on three other vital factors:

  • The Greek authorities must speak with one voice, leaving no doubt about their resolve to achieve fiscal consolidation and improve growth potential.
  • At the same time, Greece’s partners in the euro area also need to speak with one voice and commit firmly to the program, leaving no doubt about their continued financial and political support for the country’s efforts.
  • Finally, the Greek banking system will also play a crucial role in leading the way to economic recovery, by financing investment and trade, and supporting the macroeconomic and fiscal programs. So let me now turn to the prospects for the banking system.

C. The tasks for banks
The crisis has put Greek banks under strain.

  • Banks weren’t overly leveraged at the beginning of the down turn, but many of them increased their sovereign exposures in the run-up to crisis, also by leveraging available low-cost ECB refinancing.
  • With funding subsequently reduced, the system now faces a liquidity challenge. Banks have been shut off from the wholesale funding markets (except for some sporadic and costly access), and the deposit base has been shrinking due to the impact of the recession and the steady current account deficit. ECB exceptional support has helped, but will have to be unwound over time.
  • The system also faces a challenge to preserve adequate levels of capital. Non-performing loans are on the rise, dragging profits down. And the exposures to the sovereign have reduced banks’ valuations, making it important further to raise capital.

The program envisages several policy channels by which to support financial stability:
The government and central bank have the tools to provide liquidity support, within the ECB’s exceptional support mechanisms. Government guarantees for bank bonds have been effective in providing support to banks, and a new tranche is being prepared. The Bank of Greece has other instruments at its disposal as well.
For capital support, the Financial Stability Fund has been made available as a backstop for viable banks that cannot raise capital in the private market. FSF needs are regularly reviewed to make sure that the fund has adequate amounts available.

Let me stress, however, that the FSF safety net is not meant to substitute for banks’ own actions. The onus must be on banks to take care of their own problems to the maximum extent possible. Not least due to the need to achieve greater separation between banks and the sovereign. Banks will need to plan carefully to operate in this environment:
Medium-term funding plans are welcomed. The program recognizes that deleveraging cannot proceed at too fast a pace, lest it undermine asset prices and the recovery itself—a credit crunch must be avoided. At the same time, banks need to extricate themselves from the exceptional support measures provided through the euro system. The funding plans are calibrated to reconcile these tensions, so that the deleveraging can take place at a pace that is consistent with the fiscal and macroeconomic program.
Banks should further increase capital cushions. The uncertainty of how the recession and fiscal adjustment will affect the loan book calls for a capital buffer. As long as doubts exist about the assets held by banks, wholesale market access will likely remain hampered. In this regard, larger capital cushions will help to reduce these doubts.
Now, as the system adjusts to lower leverage, higher capital, and the impact of fiscal adjustment, what should we expect?
• Banks need to work closely with their clients to avoid widespread loan defaults, which could further deepen economic woes. On one side, the legal framework for private loan restructuring can be further improved to optimize this process both for banks and their clients. From the other side, the fate of the Greek sovereign and the banking system also remain closely intertwined: the government depends on banks’ continued commitment to maintain exposure. In turn, Greek banks are affected by the sovereign’s fiscal predicament, but they also depend on government guarantees for collateral and would be severely hit in any sovereign restructuring scenario.

  • Regarding deleveraging of the system, it may take some time for deposits to revive, and banks will undoubtedly make an effort to deleverage via disposal of non-core assets, the reduction of foreign exposures, and other steps as necessary.
  • The public sector needs to exit the banking system. The government’s privatization strategy envisions the sale of the government’s various stakes. This will remove allocative distortions and favor better-yielding investments through private banks.
  • Banking sector consolidation is necessary. The entry of additional first-tier international banks as strong partners would bolster the Greek banking system—both for liquidity and capital–and thereby support confidence and the economic recovery.

So, in conclusion, allow me to return to the points we made at the outset:

  • Greece stands at a critical juncture with no time to lose.
  • The past twelve months have been difficult, but the severe imbalances that have been built up over decades, bringing the economy to the brink of collapse a year ago, have been managed with more success than is sometimes recognized, even though the recession was unavoidable.
  • But good reforms have started and are gaining traction, laying the base for renewed growth. Now is not the time to slow down. Quite the contrary, this is the time to push ahead vigorously to shorten the time period to a new growth cycle.
  • Financial sector stability plays a crucial role in the recovery. The basis is there to support financial stability, and banks must do their own part. In particular, banks should seek further capital and improve markets’ perceptions of their valuation.

Finally, Greece’s growth potential and also its resilience are substantial. A fundamentally sound banking system, a reorientation toward a private-sector led investment and export performance, facilitated by far-reaching economic reforms and public sector retrenchment make for a promising mix. Full implementation of the program is essential. I am convinced that Greece will make the right choice, and as progress is made with a great effort by Greece, the IMF and other partners will gladly offer continued support.

Thank you.


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Taking control of compliance: how FS institutions can keep up with the ever-changing regulatory landscape



Taking control of compliance: how FS institutions can keep up with the ever-changing regulatory landscape 1

By Charles Southwood, Regional VP – Northern Europe and MEA at Denodo

The wide-spread digital transformation that has swept the financial services (FS) sector in recent years has brought with it a world of possibilities. As traditional financial institutions compete with a fresh wave of challenger banks and fintech startups, innovation is increasing at an unprecedented pace.

Emerging technologies – alongside the ever-evolving concept of online banking – have provided a platform in which the majority of customer interactions now take place in a digital format. The result of this is a never-ending stream of data and digital information. If used correctly, this data can help drive customer experience initiatives and shape wider business strategies, giving organisations a competitive edge.

However, before FS organisations can utilise data-driven insights, they need to ensure that they can adequately protect and secure that data, whilst also complying with mandatory regulatory requirements and governance laws.

The regulation minefield

Regulatory compliance in the FS sector is a complex field to navigate. Whether its potential financial fraud or money laundering, risk comes in many different forms. Due to their very nature – and the type of data that they hold – FS businesses are usually placed under the heaviest of scrutiny when it comes to achieving compliance and data governance, arguably held to a higher standard than those operating in any other industry.

In fact, research undertaken last month discovered that the General Data Protection Regulation (GDPR) has had a greater impact on FS organisations than any other sector. Every respondent working in finance reported that the changes made to their organisation’s cyber security strategies in the last three years were, at least to some extent, as a result of the regulation.

To make matters even more confusing, the goalpost for 100% compliance is continually moving. In fact, between 2008 and 2016, there was a 500% increase in regulatory changes in developed markets. So even when organisations think they are on the right track, they cannot afford to become complacent. The Markets in Financial Instruments Directive (MiFID II), the requirements for central clearing and the second Payment Service Directive (PSD2), are just some examples of the regulations that have forced significant changes on the banking environment in recent years.

Keeping a handle on this legal minefield is only made more challenging by the fact that many FS organisations are juggling an unimaginable amount of data. This data is often complex and of poor quality. Structured, semi-structured and unstructured, it is stored in many different places – whether that’s in data lakes, on premise or in multi-cloud environments. FS organisations can find it extremely difficult just to find out exactly what information they are storing, let alone ensure that they are meeting the many requirements laid out by industry regulations.

A secret weapon

Modern technologies, such as data virtualisation, can help FS organisations to get a handle on their data – regardless of where it is stored or what format it is in. Through a single logical view of all data across an organisation, it boosts visibility and real-time availability of data. This means that governance, security and compliance can be centralised, vastly improving control and removing the need for repeatedly moving and copying the data around the enterprise. This can have an immediate impact in terms of enabling FS organisations to avoid data proliferation and ‘shadow’ IT.

In addition to this, when a new regulation is put in place, data virtualisation provides a way to easily find and access that data, so FS organisations can respond – without having to worry about alternative versions of that data – and ensures that they remain compliant from the offset. This level of control can be reflected even down to the finest details. For example, it is possible to set up access to governance rules through which operators can easily select who has access to what information across the organisation. They can alter settings for sharing, removing silos, masking and filtering through defined, role-based data access. In terms of governance, this feature is essential, ensuring that only those who have the correct permissions to access sensitive information are able to do so.

Compliance is a requirement that will be there forever. In fact, its role is only likely to increase as law catches up with technological advancement and the regulatory landscape continues to change. For FS organisations, failure to meet the latest legal requirements could be devastating. The monetary fines – although substantial – come second to the potential reputation damage associated with non-compliance. It could be the difference between an organisation surviving and failing in today’s climate.

No one knows what is around the corner. Whilst some companies may think they are ahead of the compliance game today, that could all change with the introduction of a new regulation tomorrow. The best way to ensure future compliance is to get a handle on your data. By providing total visibility, data virtualisation is helping organisations to gain back control and win the war for compliance.

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TCI: A time of critical importance



TCI: A time of critical importance 2

By Fabrice Desnos, head of Northern Europe Region, Euler Hermes, the world’s leading trade credit insurer, outlines the importance of less publicised measures for the journey ahead.

After months of lockdown, Europe is shifting towards rebuilding economies and resuming trade. Amongst the multibillion-euro stimulus packages provided by governments to businesses to help them resume their engines of growth, the cooperation between the state and private sector trade credit insurance underwriters has perhaps missed the headlines. However, this cooperation will be vital when navigating the uncertain road ahead.

Covid-19 has created a global economic crisis of unprecedented scale and speed. Consequently, we’re experiencing unprecedented levels of support from national governments. Far-reaching fiscal intervention, job retention and business interruption loan schemes are providing a lifeline for businesses that have suffered reductions in turnovers to support national lockdowns.

However, it’s becoming clear the worst is still to come. The unintended consequence of government support measures is delaying the inevitable fallout in trade and commerce. Euler Hermes is already seeing increase in claims for late payments and expects this trend to accelerate as government support measures are progressively removed.

The Covid-19 crisis will have long lasting and sometimes irreversible effects on a number of sectors. It has accelerated transformations that were already underway and had radically changed the landscape for a number of businesses. This means we are seeing a growing number of “zombie” companies, currently under life support, but whose business models are no longer adapted for the post-crisis world. All factors which add up to what is best described as a corporate insolvency “time bomb”.

The effects of the crisis are already visible. In the second quarter of 2020, 147 large companies (those with a turnover above €50 million) failed; up from 77 in the first quarter, and compared to 163 for the whole of the first half of 2019. Retail, services, energy and automotive were the most impacted sectors this year, with the hotspots in retail and services in Western Europe and North America, energy in North America, and automotive in Western Europe

We expect this trend to accelerate and predict a +35% rise in corporate insolvencies globally by the end of 2021. European economies will be among the hardest hit. For example, Spain (+41%) and Italy (+27%) will see the most significant increases – alongside the UK (+43%), which will also feel the impact of Brexit – compared to France (+25%) or Germany (+12%).

Companies are restarting trade, often providing open credit to their clients. However, there can be no credit if there is no confidence. It is increasingly difficult for companies to identify which of their clients will emerge from the crisis from those that won’t, and whether or when they will be paid. In the immediate post-lockdown period, without visibility and confidence, the risk was that inter-company credit could evaporate, placing an additional liquidity strain on the companies that depend on it. This, in turn, would significantly put at risk the speed and extent of the economic recovery.

In recent months, Euler Hermes has co-operated with government agencies, trade associations and private sector trade credit insurance underwriters to create state support for intercompany trade, notably in France, Germany, Belgium, Denmark, the Netherlands and the UK. All with the same goal: to allow companies to trade with each other in confidence.

By providing additional reinsurance capacity to the trade credit insurers, governments help them continue to provide cover to their clients at pre-crisis levels.

The beneficiaries are the thousands of businesses – clients of credit insurers and their buyers – that depend upon intercompany trade as a source of financing. Over 70% of Euler Hermes policyholders are SMEs, which are the lifeblood of our economies and major providers of jobs. These agreements are not without costs or constraints for the insurers, but the industry has chosen to place the interests of its clients and of the economy ahead of other considerations, mindful of the important role credit insurance and inter-company trade will play in the recovery.

Taking the UK as an example, trade credit insurers provide cover for more than £171billion of intercompany transactions, covering 13,000 suppliers and 650,000 buyers. The government has put in place a temporary scheme of £10billion to enable trade credit insurers, including Euler Hermes, to continue supporting businesses at risk due to the impact of coronavirus. This landmark agreement represents an important alliance between the public and private sectors to support trade and prevent the domino effect that payment defaults can create within critical supply chains.

But, as with all of the other government support measures, these schemes will not exist in the long term. It is already time for credit insurers and their clients to plan ahead, and prepare for a new normal in which the level and cost of credit risk will be heightened and where identifying the right counterparts, diversifying and insuring credit risk will be of paramount importance for businesses.

Trade credit insurance plays an understated role in the economy but is critical to its health. In normal circumstances, it tends to go unnoticed because it is doing its job. Government support schemes helped maintain confidence between companies and their customers in the immediate aftermath of the crisis.

However, as government support measures are progressively removed, this crisis will have a lasting impact. Accelerating transformations, leading to an increasing number of company restructurings and, in all likelihood, increasing the level of credit risk. To succeed in the post-crisis environment, bbusinesses have to move fast from resilience to adaptation. They have to adopt bold measures to protect their businesses against future crises (or another wave of this pandemic), minimize risk, and drive future growth. By maintaining trust to trade, with or without government support, credit insurance will have an increasing role to play in this.

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What Does the FinCEN File Leak Tell Us?



What Does the FinCEN File Leak Tell Us? 3

By Ted Sausen, Subject Matter Expert, NICE Actimize

On September 20, 2020, just four days after the Financial Crimes Enforcement Network (FinCEN) issued a much-anticipated Advance Notice of Proposed Rulemaking, the financial industry was shaken and their stock prices saw significant declines when the markets opened on Monday. So what caused this? Buzzfeed News in cooperation with the International Consortium of Investigative Journalists (ICIJ) released what is now being tagged the FinCEN files. These files and summarized reports describe over 200,000 transactions with a total over $2 trillion USD that has been reported to FinCEN as being suspicious in nature from the time periods 1999 to 2017. Buzzfeed obtained over 2,100 Suspicious Activity Reports (SARs) and over 2,600 confidential documents financial institutions had filed with FinCEN over that span of time.

Similar such leaks have occurred previously, such as the Panama Papers in 2016 where over 11 million documents containing personal financial information on over 200,000 entities that belonged to a Panamanian law firm. This was followed up a year and a half later by the Paradise Papers in 2017. This leak contained even more documents and contained the names of more than 120,000 persons and entities. There are three factors that make the FinCEN Files leak significantly different than those mentioned. First, they are highly confidential documents leaked from a government agency. Secondly, they weren’t leaked from a single source. The leaked documents came from nearly 90 financial institutions facilitating financial transactions in more than 150 countries. Lastly, some high-profile names were released in this leak; however, the focus of this leak centered more around the transactions themselves and the financial institutions involved, not necessarily the names of individuals involved.

FinCEN Files and the Impact

What does this mean for the financial institutions? As mentioned above, many experienced a negative impact to their stocks. The next biggest impact is their reputation. Leaders of the highlighted institutions do not enjoy having potential shortcomings in their operations be exposed, nor do customers of those institutions appreciate seeing the institution managing their funds being published adversely in the media.

Where did the financial institutions go wrong? Based on the information, it is actually hard to say where they went wrong, or even ‘if’ they went wrong. Financial institutions are obligated to monitor transactional activity, both inbound and outbound, for suspicious or unusual behavior, especially those that could appear to be illicit activities related to money laundering. If such behavior is identified, the financial institution is required to complete a Suspicious Activity Report, or a SAR, and file it with FinCEN. The SAR contains all relevant information such as the parties involved, transaction(s), account(s), and details describing why the activity is deemed to be suspicious. In some cases, financial institutions will file a SAR if there is no direct suspicion; however, there also was not a logical explanation found either.

So what deems certain activities to be suspicious and how do financial institutions detect them? Most financial institutions have sophisticated solutions in place that monitor transactions over a period of time, and determine typical behavioral patterns for that client, and that client compared to their peers. If any activity falls disproportionately beyond those norms, the financial institution is notified, and an investigation is conducted. Because of the nature of this detection, incorporating multiple transactions, and comparing it to historical “norms”, it is very difficult to stop a transaction related to money laundering real-time. It is not uncommon for a transaction or series of transactions to occur and later be identified as suspicious, and a SAR is filed after the transaction has been completed.

FinCEN Files: Who’s at Fault?

Going back to my original question, was there any wrong doing? In this case, they were doing exactly what they were required to do. When suspicion was identified, SARs were filed. There are two things that are important to note. Suspicion does not equate to guilt, and individual financial institutions have a very limited view as to the overall flow of funds. They have visibility of where funds are coming from, or where they are going to; however, they don’t have an overall picture of the original source, or the final destination. The area where financial institutions may have fault is if multiple suspicions or probable guilt is found, but they fail to take appropriate action. According to Buzzfeed News, instances of transactions to or from sanctioned parties occurred, and known suspicious activity was allowed to continue after it was discovered.

Moving Forward

How do we do better? First and foremost, FinCEN needs to identify the source of the leak and fix it immediately. This is very sensitive data. Even within a financial institution, this information is only exposed to individuals with a high-level clearance on a need-to-know basis. This leak may result in relationship strains with some of the banks’ customers. Some people already have a fear of being watched or tracked, and releasing publicly that all these reports are being filed from financial institutions to the federal government won’t make that any better – especially if their financial institution was highlighted as one of those filing the most reports. Next, there has been more discussion around real-time AML. Many experts are still working on defining what that truly means, especially when some activities deal with multiple transactions over a period of time; however, there is definitely a place for certain money laundering transactions to be held in real time.

Lastly, the ability to share information between financial institutions more easily will go a long way in fighting financial crime overall. For those of you who are AML professionals, you may be thinking we already have such a mechanism in place with 314b. However, the feedback I have received is that it does not do an adequate job. It’s voluntary and getting responses to requests can be a challenge. Financial institutions need a consortium to effectively communicate with each other, while being able to exchange critical data needed for financial institutions to see the complete picture of financial transactions and all associated activities. That, combined with some type of feedback loop from law enforcement indicating which SARs are “useful” versus which are either “inadequate” or “unnecessary” will allow institutions to focus on those where criminal activity is really occurring.

We will continue to post updates as we learn more.

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