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By Simon Goldsmith, Head of Risk Solutions, SAS UK & Ireland

In December, UK bank executives breathed a sigh of relief after they all passed the annual Bank of England stress tests. It’s reassuring for consumers that financial organisations are far more able to survive another crisis now they have: slimmed down operations increased capital safety margins and pre-prepared contingency plans.

However bank stress testing teams still face two major challenges:

  • IFRS 9, the new accounting standard for calculating loan impairments, requires multi-year forecasts of individual loans under different scenarios. This is very similar to a stress testing exercise so regulators and auditors are looking for a consistent approach with explainable differences. At the moment embryo IFRS9 teams (who will first report in 2019) and stress testing teams have very different methodologies and technologies. Plans for alignment are urgently needed.
  • Quantitative Reviews: The Bank of England (BoE) still doesn’t completely trust banks’ stress testing analysis and made this very clear in the Qualitative Review section of the 2015 results. Banks must address these qualitative aspects, or risk being publically “failed”; just as the Federal Reserve System is doing in the US. The consequences of these qualitative failures are potentially identical to a capital margin failure – i.e. prevention of payment of dividends, withholding of senior executive bonuses and public censure.

This article explores these challenges further and looks into how new and emerging technologies can help.

Temperature of regulatory environment

Headlines might suggest that, for the first time since the crisis, banks can demonstrate robust five-year business plans that can withstand stormy economic seas. So far, so good. Even Mark Carney, Governor of the Bank of England, has claimed that banks are now “significantly more resilient than before the global financial crisis [and that the] post-crisis period is over”.

Yet, even though all seven banks successfully passed the test this time round, there is still a lot more to be done than simply ticking boxes. This sentiment was echoed in the stress test results announcement when it was suggested that several banks still need “to make considerable improvements, including implementing and embedding model management policies more fully”. As we’ve seen, Royal Bank of Scotland and Standard Chartered were called out by the BoE as the weakest, even though they still passed. Both were found not to have enough capital strength in the stress testing exercise. Fortunately both had already taken steps to raise additional capital before the BoE published the results.

Heightened expectations for stress testing and scenario analysis make it necessary for banks to look at risk management as not just a one-time cram session, but a year-long exercise. Being able to quickly and effectively handle any regulatory or economic scenario is essential. The current heavily manual approaches make this difficult and expensive. These expectations are not going to go away. In fact, stress testing is likely to be even stricter next year, with a much higher capital bar. That could mean a big name in hot water next time round.

Added to the challenges of regulatory stress testing come the new multi-year forecasting demands of IFRS 9. While the accounting standard was finalised in July 2014, the detailed working practices are still under debate. Recent discussions between banks, the International Accounting Standards Board (IASB) and auditors suggested an approach that would add considerable complexity to impairment forecasting calculations.

Challenges for stress testing & IFRS9 processes

Recent research by the Global Association of Research Professionals (GARP) has shown that, while progress has clearly been made and banks have improved their approach to stress testing, the technology infrastructures remain old and complex. In addition, most are not yet considering how they could exploit new IFRS9 infrastructure to enhance stress testing approaches. This limits their ability to reap the business benefits of the latest forecasting systems i.e.

  • accelerated run times
  • much lower costs of operation
  • flexibility to deliver new scenarios and
  • tight process governance and control.

This approach does not appear to be the result of budget freezes or cuts as most financial institutions have significantly increased spend on stress testing. However most of this investment has either gone into tactical extensions of existing systems or creation of additional manual processes. We regularly hear stories of demoralised employees working late into the night across many months of the year simply because too many compliance gaps have been closed with resource wasteful manual processes.

On top of this teams will need to factor in the additional workload of IFRS 9 forecasting which could be significant.  Put simply, yet more manual processes and tactical extensions won’t work and it certainly won’t close many of the regulatory governance gaps. Current systems are intrinsically too prone to error, slow and inflexible.

Key areas for future changes in stress testing architectures

The GARP report was based on a survey in spring 2015 and highlighted four areas of readiness for consideration:

  • Managing data. Banks require comprehensive data management capabilities that include data quality, data lineage and metadata documentation in a transparent and readily searchable form through the entire stress-testing life cycle.
  • Monitoring model risk and performance. Banks require capabilities to support model development as well as model governance, enabling independent review and validation of models used in internal capital planning.
  • Implementation. Model execution platforms need to perform huge numbers of calculations, while executing a variety of models on large amounts of granular-level data. These platforms must also aggregate the results to any desired level for analysis and reporting, while including process management capabilities that ensure all necessary steps are completed, monitored and repeatable.
  • Co-ordination. Banks need to specify scenarios and consolidate modelling results into balance sheets, financial statements and capital plans while orchestrating the various aspects of the stress-testing process and consolidating the results from various systems.

To GARP’s analysis from the summer we would add:

  • IFRS 9 alignment. IFRS 9 and stress testing teams need to develop and exploit a common strategic architecture. Infrastructure is likely to be developed initially for IFRS 9, then extended to provide the credit forecasting elements of stress testing.

Emerging approach being taken by leading banks

Several large banks are now developing new strategic architectures to meet both IFRS 9 and stress testing requirements. These architectures use combinations of:

  • sophisticated model development factories to efficiently develop, validate and manage sometimes hundreds of interconnected models
  • multi-model execution engines to rapidly generate detailed, multi-scenario forecasts and
  • tightly governed consolidation and reporting platforms for final review and forecast sign-offs.

Not only does this enable them to comply with today’s regulator and auditor needs, but it also provides a flexible platform to cater for inevitable changes to business, regulation and external reporting .

Banks, therefore, need to seize the opportunity to fully understand the ever-evolving state of their business and the new technology options now available. Deploying such technologies not only simplifies compliance but also releases budgets. Banks can then address what many CEOs consider bigger long term business issues – digitising their entire offerings to improve services to customers and therefore compete with new entrants to the banking sector.

Find out more about how technology can support banks with IFRS 9 compliance.


AML and the FINCEN files: Do banks have the tools to do enough?



AML and the FINCEN files: Do banks have the tools to do enough? 1

By Gudmundur Kristjansson, CEO of Lucinity and former compliance technology officer

Says AML systems are outdated and compliance teams need better controls and oversight

The FinCEN files have shown that it’s time for a change in AML. We must take a completely new approach in order to catch up with the speed of innovation in financial crime.

Despite what you’ll read in news headlines, we can’t lay all of the blame for anti-money laundering failures at the doors of the banks. The majority of compliance teams are doing what they can, and what they are being asked to do.

Historically, AML has, in large part been a box-checking exercise. Banks have weaved through mountains of false alerts, investigated cases, sent SARs, and then got on with business as usual. In some jurisdictions, banks can‘t even interfere with customers under investigation, in fear of jeopardizing cases.

But the sentiment towards banks’ responsibility in AML is changing. They are increasingly looking at AML as a corporate social responsibility issue and even a competitive advantage. Banks are looking to protect their brands from the horrors of an AML scandal, and as such are taking a more proactive approach.

They are also throwing a lot of money at the problem. Deutsche Bank claims to have invested close to $1 billion in improved AML procedures and increased its anti-financial crime teams to over 1,500 people. Most big-brand banks have a similar story to tell.

With reputation on the line, better AML controls can become good business.

So where does the problem lie?

From the thousands of SARs discovered in the FinCEN files, lack of customer oversight is evident. Banks need to establish a method of knowing their customers through their actions across the organization and beyond the organizational walls. By doing so, banks can better understand AML and compliance risk, which gives them the necessary tools to bar customers from doing business or limiting their activity.

While banks are striving to better enforce regulations by pouring money and resources into CDD and transaction monitoring, forming this type of intelligent customer overview might be the real solution. Proper Customer Due Diligence and customer risk monitoring can only be achieved by continuously tracking customer behaviour and transactional networks. With the latest developments in Artificial Intelligence – that is now possible.

But, the reality for compliance teams is they are hindered by outdated technology in their risk assessment and transaction monitoring systems and because of this, banks are fighting a steep, uphill battle against serious organised crime.

In 2019, the Bank of England issued a statement that claimed: “existing (money laundering) risks may be amplified if governance controls do not keep pace with current advancements in technological innovation.”

I know from my time working as a senior compliance technology officer that many traditional AML systems are inefficient, slow and labour intensive, and often lead to inaccurate outcomes. In fact, most of the systems pre-date the iPhone, so they are using last-generation technology and techniques to detect criminal activity.

In short, legacy AML systems are not fit-for-purpose. Legacy vendors built them for the box-checking world of the past, and they are focused on one suspicious transaction at a time – rather than looking at ‘bad actors’ in the financial system, and patterns in their behaviour.

As launderers constantly evolve their techniques to circumvent rule-based or simple statistical detection, the AML systems market has not kept up. There is a dire need for innovation.

Unless systems are updated, banks can continue to file suspicious activity reports (SAR), but if bad actors can conduct their business ‘as usual’ and shuffle money around the globe to hide its malicious origin, the effectiveness of a SAR is significantly diminished.

What’s the solution?

I believe we need to rethink our entire approach to AML. We need to empower compliance departments with better controls and oversight, and move away from outdated, traditionally rule-based systems and towards a modern, AI-enabled, behavioural approach.

While the bad guys have learnt how to evade rule-based systems, they find it extremely difficult to get around AI algorithms that search for anomalies in behaviour. The advancement of AI algorithms, especially in the field of deep learning, provide an opportunity for banks to detect more complex and evasive money laundering networks.

So the answer is to establish continuous automated risk monitoring and implement a workflow system that provides money laundering risk scores for customers.

The latest AI software could kickstart a new age of customer AML risk-based overview. Instead of relying on static and self-reported KYC data, AI systems can analyse behaviour over a period of time and compare it with peer-groups and past actions. It provides compliance teams with a continuous risk-rating of their customers, actor insights and summaries to facilitate efficient and thorough investigations, and an organizational-wide overview.

Recent advancements in AI have not only made the above possible, but also practical. Our latest Human AI models contextualize and explain the appropriate data, making it easier for banks to spot sophisticated crime.

By looking at AML not simply as a box-ticking exercise, but as a competitive advantage that can increase customers’ trust in their financial institutions, banks have a lot to gain. Moving towards behaviour-based AML systems is a move towards making money good.

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Local authorities and business networks play a key role in small business success, and must be protected during COVID rebuild



Local authorities and business networks play a key role in small business success, and must be protected during COVID rebuild 2
  • 23% of UK’s top performing businesses have been supported by local enterprise partnerships and growth hubs
  • Similarly, 30% of Britain’s strongest businesses have obtained external finance in the last 3 years
  • New findings come as part of an independent, holistic study into small business success, commissioned by Allica Bank to support British businesses

A new study, commissioned by business bank, Allica Bank, shows that a high level of engagement and interaction with external institutions and resources, is central to SMEs’ prospects of success.

The study analysed data from over 1,000 companies and ranked their success on a scale that evaluated factors including productivity, growth, consistency and outlook. To measure SMEs’ external engagement, survey respondents were asked whether or not they had engaged with local enterprise partnerships, growth hubs, or external financial advisers, as well as whether they had obtained credit or sought re-financing advice, in the last three years.

The benefit to small businesses in making the most of external resources are clear to see, with a quarter (23%) of the UK’s top performing SMEs – those in the top tenth percentile – actively engaging their local enterprise partnership or growth hub in the last three years. This compares to just 16% of all other small businesses. With such a clear benefit to businesses, these external networks must not only be protected but prioritised by any Government plans to rebuild the economy post-COVID.

Similarly, of the top performing SMEs in the country, 30% have obtained external credit in the past three years, compared to less than a quarter (24%) of all other businesses. This figure drops even further for the weakest performing businesses – those in the ninetieth percentile – where just 12% of businesses have obtained external financial support in recent years.

Chris Weller, Chief Commercial Officer, Allica Bank, said:

“At Allica Bank we understand that no two businesses are the same. We also know that no-one knows a business as well as its owners and managers. But they can’t be expected to be experts on everything.

“In the UK there is a wealth of external advice and support for small businesses and we urge each and every business out there to tap in to the external resources around them. Third-parties, such as business clubs, chambers of commerce, local enterprise partnerships and trade bodies, can be invaluable sources of advice and further resources. And although they have excelled in their given field, business owners may still lack knowledge in many other areas of running and growing a business. Therefore, engaging with third parties can give business owners the kinds of insight – and fresh perspectives – they need to succeed.

“As the economy and the country comes to terms with the impact of the COVID-19 pandemic, it is important these vital SME resources are protected and given the funding they need to continue providing invaluable insight and support to small businesses up and down the country.”

Allica Bank’s SME Guide to Success identified six ‘rules to success’ that were more likely to be displayed by top-performing SMEs compared to their counterparts. The full report contains a wealth of additional data and insight into each of these topics.

As part of its mission to empower small businesses, Allica Bank is making the findings freely available and running a series of free online workshops with relevant partner organisations for businesses to attend.

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Do we really need banks? Yes, but digital transformation industry-wide is vital



Do we really need banks? Yes, but digital transformation industry-wide is vital 3

By Charley Cooper is Managing Director at enterprise blockchain firm, R3

The Coronavirus crisis has taught us that we are capable of going digital quickly when we need to. As the banking sector faces a second wave, the ability for individual firms to grow and succeed will be reliant on better connectivity and efficiency at the industry-level, writes R3’s Charley Cooper.

The sudden and dramatic pace of change has been seen globally over the last six months. Decades of paper-based practices are being updated, digitised and overhauled as the whole word adapts to working online. As of today, countries are accepting “alternative arrangements” for original paper export certificates, New York is allowing notary services by video, and global banks are accepting “original” documents and acceptances by email.

Over the coming months, we will see this digital transformation extend from individual use cases and firm-level deployment to entire industries. And perhaps in no other industry is this more critical than in financial services, where the role of banks continues to be challenged because of the inefficiencies they face as a result of decades of siloed technology deployment.

While unquestionably an improvement over reliance on manual processes, regular “digital transformation” as implemented by a single bank has limited benefits. These typically include greater automation of business processes, acceleration in adoption of electronic channels, elimination of manual processes, standardisation of non-value-adding business practices and a focus on driving up data quality and speed of information flows.

Now consider achieving digital transformation at the level of the entire market, rather than on a bank-by-bank basis. Whilst a digital transformation project for a single bank might automate a business process between a front and back office, a digital industry transformation project might optimise the trading and settlement of the asset between buyer and seller and their custodians too.

Of course, such things have been attempted before. But there have been many failures and the successes are notable by how they have resulted in new dominant centralised providers – for example for market data, messaging or settlement. The advent of blockchain architectures showed us there was a new way to tackle the problem, one that worked with the grain of existing markets.

Done right, the prize is a huge “productivity dividend” as entire markets are unshackled from their analogue histories.

Tackling interbank reconciliation at the industry level

The Italian financial services industry provides a pertinent use case of digital industry transformation. 32 banks in Italy went live in March with one of the first real-world deployments of enterprise blockchain technology in interbank financial markets. 23 more banks went live in May, with further institutions scheduled to go live this autumn. Built by the Italian Banking Association, ABI, the Spunta Banca DLT app on R3’s Corda Enterprise platform tackles the market-wide issue of interbank reconciliation.

The traditional reconciliation process for interbank transactions in Italy—formerly governed by the “spunta” process— is notoriously complex. Resolving mismatches in transactions is a labour-intensive process, hampered by a lack of standardisation, fragmented communication and no “single version of the truth.” The Spunta Banca DLT app automates the reconciliation process and enables banks to pinpoint mismatches in interbank transactions quickly by sharing common data in a secure way.

Connecting such a large and diverse group of banks in a live environment to tackle a shared problem is a major milestone for digital transformation in the Italian banking sector, providing a glimpse into a brighter, more efficient and interconnected future for all financial markets.

Changing mindset

The current crisis has accelerated the launch of digital technology for many use cases across a diverse range of sectors, but those that stand the test of time will be developed with an industry-level mindset, not firm-level.

It is now clear that the age of inter-bank optimisation is over – the path forward from this crisis will be paved by software that focuses on adding real value for entire markets, connecting banks to overcome the biggest challenges they share as an industry.

Banks must adapt and start thinking about technology in new and innovative ways if they are to retain their critical role in the global economy.

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