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MIFID II – AS THE GREEKS WOULD SAY, “THERE IS NO AVOIDANCE IN DELAY”

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MIFID II – AS THE GREEKS WOULD SAY, “THERE IS NO AVOIDANCE IN DELAY”

Jeremy Taylor and John Downing, GFT

The MiFID II ‘monster’

The 27th September 2015 was the day when the 1,285 pages of MiFID II technical and implementing specifications, plus the revised cost / benefit analysis arrived on our electronic doorsteps. I think it was also the day when we collectively realised that what we had feared was in fact becoming a reality: that this regulation was much bigger and more complex than we had ever anticipated.

The specificity of all three documents spelt out in excruciating detail the ways in which MiFID II was going to be required to be implemented by all of the banks in Europe. It shouldn’t have been too much of a surprise; the concern was simply the enormity of the job facing us all across the industry. All that was missing was any deviation in the expected delivery date – 3rd January, 2017. The banks were also being told by the regulators that the date was fixed, that there was no time to renegotiate any Level 1 or Level 2 changes, and that there were more specifications to come.

ESMA requests a delay

Imagine our surprise then, when on the 10th November, Steven Maijoor, the Chairman of the European Securities and Markets Authority (ESMA) delivered a statement to the Economic and Monetary Affairs Committee (ECON) at the European Parliament requesting a delay to the implementation date. He cited that the timing for stakeholders and regulators alike to implement the rules, and build the necessary IT systems, was going to be “extremely tight”, and that there were already a few areas where the calendar is already unfeasible. This related to the fact that it will be well into 2016 before the complete text of the regulatory technical standards (RTS) will be stable and final. The building of some of the complex IT systems can only really start when these final details are firmly set, and most of the required IT systems will then need at least a year to be built, tested and commissioned.

The notes that accompanied his delivery (dated 2nd October – just one week after the publication of the initial RTS), makes reference to this possible delay by stating that “in the last couple of months, it has become evident for ESMA and National Competent Authorities (NCAs) that it will not be feasible to have those systems ready for 3rd January 2017.” So, it seems that way back in the early summer of this year, there was already the realisation that the January 2017 date was not feasible. His note also covered some of the technical and legal details to be considered, along with three scenarios for deferring the implementation date.

A period of uncertainty

We are now, therefore, in a period of great uncertainty, whilst ESMA and the European Parliament decide which of the three alternative scenarios is the best possible outcome for the European Parliament, its ECON, ESMA, the NCAs, and the financial services industry in Europe as a whole.

Following the publication of the note, subsequent press and media reports are starting to give credence to probability of a delay. We believe that any delay would be greeted by the regulatory bodies and the affected banking firms with equal sighs of understanding and relief. It would give us all more time to do it right, first time, with no compromise. All other legislation and regulation which would be affected by such a change in implementation date would, by necessity, also need to be adjusted so as to bring a harmonised approach to such a delay.

How best to use whatever additional time is provided?

In no circumstances should we take our collective feet ‘off the pedals’. We have already firmly pushed to the floor to get our arms around this regulatory monster. We need to continue to read the small print in all of the 27 work streams (if available), and determine which instruments we will want to trade in and how and where these trades will be settled.

Given the exponential increase in instruments now within the mandate of MiFID II (collectively maybe 15,000,000 unique instruments), the increase in transparency (pre-and-post-trade, and transaction, reporting), and improved investor protection (professionals treated like retail clients in some respects), now is the time to determine how all of our operating models will change, across all asset classes.

The traditional vertical functional silos in our back and middle offices can and should be aligned horizontally to simplify the processing. The fluid nature of whether an instrument is ‘liquid’ or ‘illiquid’ will very likely cause major interruptions in their treatment in the back and middle office spheres. The need to reconcile trades, positions, profit & loss, and risk with a CCP, non-CCP, and regular OTC could in fact significantly increase the operational risk in settling and managing the events in the life of all derivative trades.

Any pause will also allow valuable extra time to review new technologies, to see if they can provide any benefit in creating a MiFID II solution going forwards.

A fundamental change for all participants

An important point to note is that this request for an implementation delay has come from the regulators for the benefit of the regulators, who have accepted that the infrastructure they require to support the regulation is epic in its proportions, and will take longer to build if it is to meet its objectives. It is also vital in ensuring that data shared between NCA’s ensures that limits and caps are correctly set.

This provides market participants with the best evidence yet that this piece of regulation will fundamentally change the way that firms interact with one another, the market and clients. Major business and operating model decisions need to be made quickly, and feasibility studies completed on how best to adapt to the new rules. There are choices to be made on whether to become Multilateral Trading Facilities (MTF), Organised Trading Facilities (OTF), Systemic Internalisers (SI), or some combination of all three. This implies material change to the way trades are captured and piped to downstream systems for processing and reporting.

All in all, despite the appearance of more time being made available, it is vital that firms conduct a full impact study now in order to give themselves sufficient time to build and adapt their business and system architectures in time.

As such, a quote from a classic Greek tragedy resonates perfectly and rings true for MiFID II; “There is no avoidance in delay”, meaning that firms should keep their feet firmly on the accelerator!

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Investing into a more sustainable future: changing businesses from the inside out

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Investing into a more sustainable future: changing businesses from the inside out 1

By Shawn Welch, Vice President and General Manager of Hi-Cone Worldwide

As industries across the world are facing unprecedented uncertainty and anticipating the economic implications of the current health crisis, business leaders have the unique opportunity to seize the chance to make lasting, positive changes and re-interpret the business challenges in a positive way – without forgetting or minimising the toll the pandemic has taken. When trying to identify a way forward, the future must be sustainable. We must take this opportunity to find a more sustainable way for businesses and manufacturers to survive.

Environmental and economic concern have only increased the gap on what consumers want – more sustainability – and how much progress businesses can make without risking their viability. However, rather than giving up on ambitious goals, maybe we need to reframe the way we look at sustainability. So far, businesses have tended to react to consumer demands, often without looking into the long-term implications and research-based due diligence one would expect. Therefore, now is the right time to be more deliberate: to continue on the path towards a truly sustainable ‘new normal’, businesses need to consider the bottom line impact more than ever before and truly invest in changing their business models to become more sustainable.

Shawn Welch

Shawn Welch

To meet the UN’s ambitious 2030 Sustainable Development Goals, businesses ultimately must thrive – working towards establishing a circular economy remains crucial. Instead of a linear ‘extract, use, dispose’ approach, materials need to be respected and re-used as many times as possible, which is only possible if products are designed for re-use, re-manufacturing, repair or restarting. After all, any and all consumption comes at a price. In manufacturing, processes draw on resources to produce items that, once they have served their purpose, become surplus to requirements. Yet, to ignore this is to take an incomplete view of sustainability: instead, materials are extracted from waste to re-enter production processes. Reuse and recycling initiatives are central to this and great strides have been made in raising awareness of this need. The full environmental cost of production and consumption includes the choice of materials themselves but also the level of carbon emissions generated, and energy consumed.

Once products and processes have redesigned for a circular approach, this initial investment will often easily be recouped, especially if we start with looking at the facts when starting this crucial process. To make the Circular Economy a focus for any business very often means changing the business model. Here, investing in research and development is vital. In the packaging industry, for example, we are seeing that customers and consumers are increasingly more focused on sustainability, and that surprising changes can unlock societal and business value. Through minimising a product’s carbon footprint or making recycling easier for consumers, lifecycle-assessment-based product redesigns or using recycled plastics instead of larger quantities of cardboard, companies are identifying these more creative options and enjoying the long-lasting benefits that come with implementing them. In any case, leadership is key. A research-driven approach gets everyone on-board and seeing management committing to these goals as part of business plans helps cement these. At a recent Reuters Responsible Business Summit virtual panel, I was part of an interesting conversation. Here, Yolanda Malone, Vice President Global R&D Snacks PKG, PepsiCo, discussed how leaders have to drive the behaviours within the organisation and the tone for the culture. She explained that her sustainable plastics vision is a world where plastics never become waste. Only through putting the mantra of “reduce, recycle, rethink and reinvent” can we bring circular products to consumer. She stressed that, if we don’t reinvent, we will fall back into old habits.

Of course, consumer behaviours play a part and the easier the solution, the more likely consumers will get behind it. End consumers are becoming increasingly conscious of packaging. So, to be truly circular, we need to take into account the entire lifecycle. Mindset change needs to continue to happen. Consumers need to be clear about what their choices are. To achieve this, we must change our businesses from the inside out, allowing for close collaboration inside and outside of our organisations. Other organisations – such as governments and recycling organisations – will need to be involved in businesses’ efforts, multiplying the impact our investments will have. We must address all aspects of sustainability and, for example, have better recycling, a focus on infrastructure and emphasis on consumer education. To recover, reuse and recycle, the R&D must be in place and dedicated to sustainability. Partnerships are important as we, as other leading global companies realise, cannot do this alone. Collaboration is key when investing in a more sustainable, more Circular, future.

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Securing Information Throughout the Supply Chain – Preventing Supplier Vulnerabilities 

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Securing Information Throughout the Supply Chain – Preventing Supplier Vulnerabilities  2

By Adam Strange, Data Classification Specialist, HelpSystems 

The financial services sector is experiencing extreme disruption coupled with rapid innovation as established institutions strive to become more agile and meet evolving customer demand. At the same time, new market entrants compete fiercely for customers. Increasing operational flexibility, through the deployment of cloud infrastructure or via digital transformation initiatives, is critical for future competitiveness but it has also driven regulatory and security challenges, particularly around working with suppliers.

That said, the benefits of a diverse, interconnected supply chain are compelling: agility, speed, and cost reduction all weigh on the positive side of the equation, prompting financial institutions to pursue close, collaborative relationships with suppliers, often numbering in the hundreds or thousands.

Weakness in the supply chain

On the negative side is the increased cyber threat when enterprises expose their networks to their supply chain. In our modern interconnected digital ecosystems, most financial organisations have many supply chain dependencies and it only takes one of these to have cybersecurity vulnerabilities to bring a business to its knees.

As a result, breaches originating in third parties are common and costly – a Ponemon Institute/IBM study found that breaches being caused by a third party was the top factor that amplified the cost of a breach, adding an average of $370,000 to the breach cost.

Concern around the supply chain was also evidenced in a recent report we have just issued, whereby we interviewed 250 CISOs and CIOs from financial institutions about the cybersecurity challenges they face and nearly half (46%) said that cybersecurity weaknesses in the supply chain had the biggest potential to cause the most damage in the next 12 months.

But sharing information with suppliers is essential for the supply chain to function. Most financial services organisations go to great lengths to secure intellectual property, personally identifiable information (PII) and other sensitive data internally, yet when this information is shared across the supply chain, does it get the same robust attention?

Further amplified by COVID-19

Financial service organisations have always been a key target for cyber attacks.  Our research showed that since COVID-19 hit, the risk has elevated further, with 45% of the respondents seeing increased cybersecurity attacks during this period. Likewise, hackers are rejecting frontal assaults on well-defended walls in favour of infiltrating networks via vulnerabilities in suppliers.

But financial services organisations must maintain reputations and ensure customer trust. Firms are keen to demonstrate that they are protecting customer assets, providing an ultra-reliable service and working with trustworthy partners. So, what can they do to better protect their supplier ecosystem?

At the very least, they need to ensure basic controls are implemented around their suppliers’ IT infrastructure.  For example, they must ensure suppliers maintain a secure infrastructure with a minimum of Cyber Essentials or the equivalent US CIS certification controls. Cyber Essentials defines a set of controls which, when implemented, provide organisations with basic protection from the most prevalent forms of threats, focusing on threats which require low levels of attacker skill, and which are widely available online.

Likewise, they need to ensure good information management controls are in place and this begins with accurate information/data classification. After all, how can you apply appropriate controls to your information unless you know what it is and where it is?

How ISO27001 helps organisations put in place a data classification process

The international standard on information security, ISO27001, describes the basic ingredients for data classification to ensure the data receives the appropriate level of protection in accordance with its importance to the organisation. It comprises three basic elements:

  • Classification of data – in terms of legal requirements, value, criticality and sensitivity to unauthorised disclosure or modification.
  • Labelling of data – an appropriate set of procedures for information labelling should be developed and implemented in accordance with the organisation’s information classification scheme.
  • Handling of assets – procedures for the handling of assets developed and implemented in accordance with the organisation’s information classification scheme.

Adoption of this methodology will help financial services organisations and their supply chain take a more data-centric information security approach. However, there are essentially four key stages for implementing a data risk assurance supply chain approach and these are:

 1. Approval – in organisations with complex supply chains senior management, vendor management, procurement and information security will all need to support a robust risk-based information management approach. Details of previous incidents and their impact alongside the business benefits will be essential to gain stakeholder buy in.

 2. Preparation – Organisations should start with Tier 1 suppliers and initially identify the contracts with the highest business impact/risk. They should identify and record information repositories and the data that they contain together with the responsible business owners. Define a business taxonomy based on information categories of that data and include supply chain factors such as what information categories are shared.

For example, they need to understand the business impact of compromise against each of the information categories. Have any suppliers suffered security incidents? What assurance mechanisms are in place? Once all this information is collated the organisation can create a data classification policy and define a set of controls for each data category.

 3. Discovery – Select each data category and identify the associated contracts. Then prioritise the data category based on the risk assessment and verify that the data security controls and arrangements for each data category and contract meet the overall requirements. Once complete, hand over the contract for inclusion in the vendor management cycle.

4. Embed process – the overall objective is to embed information risk management into the procurement lifecycle from start to finish. Therefore, whenever a new contract is created there are a number of actions required which embed data risk at each stage of the bid, tender, procurement, evaluation, implementation and termination phases of the contract.

To summarise, organisations should start by researching the information risk and security frameworks such as ISO27001 and others. They should then focus on defining their business taxonomy and data categories together with the business impact of compromise to help develop a data classification scheme. Finally, they should implement the data classification scheme and embed data risk management into the procurement lifecycle processes from start to finish. By effectively embedding data risk management and categorisation into their procurement and vendor management processes, they are preventing their suppliers’ vulnerabilities becoming their own and are more effectively securing data in the supply chain.

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Deloitte: Middle East organizations need to rethink their workforce in the wake of COVID-19

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Deloitte: Middle East organizations need to rethink their workforce in the wake of COVID-19 3

Organizations in the Middle East have had to take immediate actions in reaction to the COVID-19 pandemic, such as shifting to remote and virtual work, implementing new ways of working and redirecting the workforce on critical activities. According to Deloitte’s 10th annual 2020 Middle East Human Capital Trends report, “The social enterprise at work: Paradox as a path forward,” organizations now need to think about how to sustain these actions by embedding them into their organizational culture.

“COVID-19 has created a clarifying moment for work and the workforce. Organizations that expand their focus on worker well-being, from programs adjacent to work to designing well-being into the work itself, will help their workers not only feel their best but perform at their best. Doing so will strengthen the tie between well-being and organizational outcomes, drive meaningful work, and foster a greater sense of belonging overall,” said Ghassan Turqieh, Consulting Partner, Human Capital, Deloitte Middle East.

According to the Deloitte report, many organizations in the Middle East made quick arrangements to engage with employees in the wake of the pandemic through frequent communications, multiple webinars where senior leaders addressed employee concerns, virtual employee events, manager check-ins, periodic calls and other targeted interactions with the workforce.

The report also discussed how UAE and KSA governments have reexamined work policies and practices, amended regulations and introduced COVID-19 initiatives to support companies and the workforce in the public and private sectors. Flexible and remote working, team-building and engagement activities, well-ness programs, recognition awards and modern workspaces are among the many things that are now adding to the employee experience.

Key findings from the Deloitte global report include:

  • Only 17% of respondents are making significant investments in reskilling to support their AI strategy with only 12% using AI primarily to replace workers;
  • 27% of respondents have clear policies and practices to manage the ethical challenges resulting from the future of work despite 85% of respondents saying the future of work raises ethical challenges;
  • Three-quarters of leaders are expecting to source new skills and capabilities through reskilling, but only 45% are rewarding workers for the development of new skills; and
  • Only 45% of respondents are prepared or very prepared to take advantage of the alternative workforce to access key capabilities despite gig workers being likely to comprise 43% of the U.S. workforce this year according to the Bureau of Labor Statistics.

“Worker well-being is a top priority today, and similarly to the rest of the world, companies in the Middle East are focusing their efforts to redesign work around well-being by understanding workforce well-being needs,” said Rania Abu Shukur, Director, Human Capital, Consulting, Deloitte Middle East.

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