We attended SIFMA’s Anti-Money Laundering & Financial Crimes Conference last month where experts in the industry discussed legal and regulatory developments, enforcements, and industry perspectives. There were many discussions around whistleblowers, anti-bribery & corruption, securities fraud and even marijuana related securities legislation.
Andrew J. Ceresney, Director of Enforcement at the U.S. Securities and Exchange Commission, gave a keynote address on these important elements of compliance:
Our team of experts attended to discuss how we help our clients navigate the evolving financial crime landscape by reducing cost, improving efficiency, and overcoming reputational, operational, and financial risks associated with anti-money laundering and regulatory compliance initiatives. A sound AML and KYC policy and reporting procedure must be in place to monitor and prevent fraud and money laundering. If you happen to be a target or a subject of a federal investigation, you must have crossed your t’s and dotted your i’s when it comes to the adequacy and effectiveness of SAR content and sanctions screenings.
We’re currently working with one of the world’s largest financial services institutions in an anti-money laundering (AML) initiative where we are leveraging for our client our team’s extensive banking, payment and regulatory expertise and a proven track record of industry success. For the summit, our AML and compliance experts at Perficient put together this presentation around our core capabilities as they related to AML and financial crimes. It is an 8-point approach to AML, risk and compliance for financial services firms, including: Know Your Customer, Customer Due Diligence, Anti-Bribery and Corruption, Global Payments, Sanction Programs, Cyber Security & Privacy Regulations, Anti-Money Laundering, Fraud Protection, and Regulatory Compliance.
Regulatory change, budgetary constraints and rapid changes in technology are making it hard for financial firms to transform for tomorrow while managing the challenges of today. Our guide, “Transform for Tomorrow”, can help.
Contact Us to Learn More.
If you had not heard about the latest NFL scandal with the New England Patriots leading up to the biggest football game of the season (the Super Bowl) surely you did during some of the coverage of the game. National news took time out of their normally depressing nightly news to cover the latest developments in Deflategate. I’ll preface this story by saying I’m a Patriots fan and I’m quite used to being heckled by my friends for liking “America’s (Most Hated) Team”. However, there are many people that do not feel the same about New England regardless of the now four Super Bowl Championships they’ve won in the past two decades, their dominance in the AFC under Bill Belichick’s leadership, and with Tom Brady, one of the greatest quarterbacks of all time, at the helm (but I digress).
So you may be asking me, “What’s your point to this story? How possibly can Deflategate equate to lessons learned in financial services? Let me connect a few dots.
If you’re not following the story, the NFL has spent the last several weeks conducting a very thorough investigation into the New England Patriots after the AFC Championship game where they were accused of having 11 of 12 footballs “underinflated”. Immediately news of these mysteriously deflated footballs spread like wildfire on social media and the Patriots were bombarded by media and critics asking questions and lashing out calling them cheaters. The Deflategate debate raised several questions:
“Would the controversy taint the Patriots’ dynasty?”
“Would Deflategate overshadow or discredit a Patriots Super Bowl victory?”
“Will these allegations tarnish Tom Brady or Bill Belichick’s reputation and keep them out of the NFL Hall of Fame?”
Message to the New England Patriots: The Importance of Managing Reputational Risk
While the investigation is still ongoing and no one has been found guilty of purposefully deflating the teams’ game balls, these allegations surrounding the Patriots have potentially tarnished their reputation with outsiders and maybe with league officials. While you could point fingers at Bob Kravitz for leaking the story and portraying the Colts as sore losers or Roger Goodell for how the investigation has been handled, ultimately this falls on the shoulders of Robert Kraft, Bill Belichick and Tom Brady.
What has been the effect on the Patriots organization as a result? The perception of the organization’s trust-worthiness and question of whether this potential rule violation compromises the integrity of the game has resulted in reputational risk. So what exactly is reputational risk and how can financial firms relate to managing risks similar to what the Patriots are facing?
Reputational risk is defined as a risk of loss resulting from damages to a firm’s reputation, in lost revenue, increasing operating, capital or regulatory costs; or destruction of shareholder value, consequent to an adverse or potentially criminal event even if the company is not found guilty.
Since, a bank’s business model is primarily built on public trust, it’s essential firms avoid risks that can undermine trust and potentially result in financial loss. Similar to the Patriots, financial firms need to have a framework in place to help identify, escalate, and resolve reputational risks that may arise from business activities of the bank.
Here are 5 keys to managing reputational risk based on the exercise the Patriots have gone through with Deflategate as the organization and certain individuals were forced to defend themselves:
Message for the NFL (and Regulators): Ensuring Compliance of Rules and Regulations
Just before the Super Bowl on Sunday, the news broke that the NFL had neglected to record the actual PSIs of the Patriots’ game balls. What did that mean for Roger Goodell and Wells’ Deflategate investigation? It means a lot when it comes to having irrefutable evidence to convict the Patriots of purposely deflating the footballs. The balls are simply “approved” or “disapproved” before the game. In other words, the NFL is taking the referee’s word that they were set to 12.5 PSIs. It wasn’t clear if the balls were just slightly under-inflated due in part to a change in temperature (if at all) and that won’t sit well in the minds of many.
Here are 3 keys to managing reputational risk from a regulatory agency’s perspective and how financial institutions play a role in helping to shape relationships with regulators:
While most banks have a better grip on Know Your Customer requirements than they did years ago, the challenges and risks of non-compliance continue to grow as regulators focus on sources outside the financial institutions’ walls. What is the impact of a failed risk management program as a result of actions committed by a vendor or service provider? Your financial institution may be exposed to reputational damage and multi-billion dollar fines.
During our webinar “Navigating the Financial Crimes Landscape with an Effective Vendor Management Program” last week, we explored this newer risk management focus area that is surfacing as a top strategic priority for banks in 2015.
Our speaker and regulatory compliance expert covered the complexities of the growing financial crimes landscape and potential areas of risk associated with third-party relationships. Some key takeaways for attendees included:
Below is a copy of the Slideshare deck from the webinar. Also, join us for Part 2 in our 2015 Risk and Compliance Webinar Series next week as we explore, “How to Drive Value from Operational Risk Data”.
Digital has permeated almost every facet of our lives as consumers in an “always on” connected world. In fact, it’s even impacted how we, as a company, serve our clients across industries based on their top priorities and challenges to better reach and serve their customer base – and the financial services industry is no exception. Over on our new Digital Transformation blog, Michael Porter, highlighted a story from Information Age around the first UK “digital-only” bank Charter Savings Bank launching. While I’d argue that they’re not the first, nor will they be the last – considering how hot the fintech market is right now – the main premise of the story is definitely relevant to the paradigm shift the financial services industry is experiencing. And we’re not the first thought leaders to be talking about it – Chris Skinner, Brett King, Brad Leimer and Ron Shevlin are all advocates for digital banking or neobanking.
We’re seeing both digital disruption AND digital transformation across the board in financial services. Not only in retail banking, but in wealth management, investment banking, capital markets, insurance and payments. Michael makes an interesting statement in his blog post that I’d debate:
“…digital transformation drives disruption.”
I’d argue that it’s the reverse that’s actually happening in financial services. The consumerization of mobile technology, APIs, cloud services, wearables and the like are enabling technologies or “digital disruption” that have relevance in the industry, and brick-and-mortar banks, payment companies, insurers and other traditional financial services providers are having to find ways to embrace digital transformation as a result.
Furthermore, non-traditional financial services providers and technology innovators (a.k.a. digital disruptors) like Apple, Google, Amazon, Uber, Simple, and PayPal, are changing the digital banking game for the Wells Fargo’s, Bank of America’s, Citibank’s of the world. All of these financial institutions are having to re-platform their products and services to satisfy three primary goals:
While we may never really see a “Google Bank” per say (because it doesn’t need to), they are disrupting the traditional relationship with the financial customer. In both retail banking and institutional segments, digital’s pervasiveness in the industry is forcing financial institutions to redefine how they deliver value to their customers with their products and services – all through what we call digital transformation. While, it may take on many different shapes or forms for your organization (evolving the mobile banking customer experience, the use of big data and analytics, digital marketing, etc.) one thing is certain – digital transformation is imperative!
There will undoubtedly be a wide range of financial services predictions and banking trends that will surface throughout the year which will make planning your organization’s top priorities in 2015 increasingly difficult. However, one thing is certain – risk and compliance continues to move to the top of the executive’s agenda. As financial institutions continue to experience an onslaught of cybersecurity threats, a growing financial crimes landscape and increasing regulatory demands, the need to prepare for several long-term risk and compliance trends is apparent. To help get you on the fast track to success with your New Year’s resolutions, here are six risk and compliance trends you should make a top priority in 2015.
For a more in-depth discussion on effectively managing the evolving financial crimes landscape and the growing role of operational risk management, join our 2015 Risk and Compliance Webinar Series in January.
The clock is ticking as we are fast approaching the end of 2014 and are already focused on what’s ahead in 2015. Before we take a jump ahead into the next calendar year, I thought I’d give readers a look back at some of the great content produced this past year. Visit our Thought Leadership section of our website for more great content. Be sure to stay tuned for more posts as we take a sneak peek at the top priorities and industry trends that will position today’s leading firms at the forefront of innovation!
Perficient Financial Services National Practice
Transform for Tomorrow: Navigating New Forces in Financial Services a White Paper by Various Contributors
Building a Customer-Centric Model in Financial Services a Perficient Perspective with Hemant Jaiswal, Director of Wealth Management, Perficient
Investment Product Reengineering: Optimizing Sales Enablement for Asset and Wealth Management Firms a White Paper by David Wiesel and Vince Orzo
Improve Efficiency, Compliance and Productivity Through Finance Transformation in Financial Services a Webinar with Sanjay Balan, Director, Perficient
Success Factors for Ensuring Regulatory Compliance with CCAR/DFAST Programs a Feature Article (original source on Wall Street Technology Association) by Rich Brownstein, Director of Risk and Compliance, Perficient
Overcoming Strategic Challenges of Dodd-Frank a White Paper by Chris Skinner
From the Financial Services Blog
This morning I got to work and went through my usual routine of catching up on the news online, posting articles on social media, and taking a quick scan of my Facebook feed. One particular Facebook post from one of my younger friends caught my attention. He and his wife recently adopted a child and I’m sure have been receiving a lot of paperwork these days as they go through open enrollment for medical insurance and things of that nature. They also started a college fund for him with large financial services company (which I will leave nameless). They just returned from a trip to Colorado and were going through the stack of mail to find six, yes six, letters from the wealth management firm all just regarding the confirmation of the account being setup for their son.
His comment is around the topic of “digital” that is often debated in the the financial industry (and other sectors too). In fact, I recently interviewed our wealth management practice director for our Perficient Perspectives series, “Building a Customer-Centric Model in Financial Services”. As part of this Q&A series we talked about the demand for digital during all phases of the customer interaction lifecycle – from engagement, transaction, and fulfillment to servicing the client. The pile of paperwork my friend received is a perfect example of where, even with little interactions, customers react to certain processes and interactions with their financial services provider. Not to mention, if this is the “typical” amount of paperwork a new client receives during the on boarding process, then I cannot imagine what the financial services company is spending to create, print and mail these documents to all of their clients! Then throw in the monthly or quarterly statements regarding a client’s assets or accounts – what kind of reaction does this cause? Well, here’s a quote from Hemant Jaiswal from our interview that puts it into perspective:
…we’re at a tipping point in the industry. Financial services companies must adopt more customer-centric operating models going forward or risk becoming irrelevant with consumers and corporate clients.
Research shows that this industry challenge and paradigm shift exists beyond Millennials and younger generations. In fact, according to the recent Capgemini and RBC Wealth Management World Wealth Report 2014, “nearly two-thirds of clients with at least $1 million or more in investable assets expect to manage most of their wealth relationships digitally in five years,” and these clients “would consider leaving their current firm if an ‘integrated channel experience’ is not provided.
Unfortunately, digital transformation for banks and financial services companies isn’t something that can happen over night either. For many of the larger financial firms, this is a multi-year engagement that requires a lot of integration and consolidation of legacy systems to reach the desired target state operating model. Throw in the demand for new mobile technology and digital marketing tactics, and the struggle to reach digital nirvana seems insurmountable or unobtainable. The below graphic represents a high-level overview of our approach to helping banks and financial services companies transform for tomorrow through new digital capabilities. To learn more about industry trends and how Perficient is helping top-tier financial institutions solve business and technology challenges, read the full Perficient Perspective with Hemant Jaiswal.
Many of Monday’s sessions at Money20/20 focused on the retail and commerce space. From demos of new payment platforms and systems, the use of BLE and beacon technology, the future of gift cards and prepaid to research on consumer shopping behaviors, its evident that the emerging trends and innovations in these areas are spilling over into the financial services and banking industry. Many of the attendees that stopped by our booth or that we talked to during sessions were here for two primary reasons. One, to look for answers and solutions to deal with current challenges. Two, to find out what’s next in payments in order to keep pace or move ahead of the pack.
In reflecting back on those sessions, opening remarks and Monday’s keynotes, I’d group most of the insights shared, business discussions had, and technology innovations we saw into three primary areas: those that are driving convergence and those that are disrupting the industry. Similarly, here are some Money20/20 highlights and emerging trends from Day 2 presented in a similar manner:
Payments Disruption Escalates
Bitcoin is everywhere at Money20/20! In fact, as of the end of September there were $5 billion worth of bitcoins in circulation. However, there still seems to be a lot of uncertainty around digital currency and how compatible the traditional financial system is with the new online and digital world people are shopping and transacting in. While banks are more heavily focused on digital banking services in other areas such as online and mobile banking, some banks are starting to experiment with this payment network in their innovation labs. Bank Systems & Technology offers some advice for development on the Bitcoin Blockchain and where banks should start.
During McKinsey’s keynote they highlighted six major payments “themes” and cryptocurrency was one of them. They identified four potential applications:
Bitcoin is indeed a departure from existing payment vehicles and is breaking barriers to traditional financial services. While there is support from PayPal and appeal from merchants, many believe there is far-reaching potential with Bitcoin but a lot needs to happen in terms of development and regulations before it truly disrupts the financial system at its core. During a session with Circle founder, Jeremy Allaire, said he believed banks were a few years away from integrating Bitcoin stating, “banks are reluctant to get into this market until they have a better understanding of the obligations under existing laws and regulations. I think they are reluctant to work with other companies if they are directly involved until they have that clarity.”
Opening the Doors for Digital Convergence
For the most part, a large number of new services and products we’re seeing at Money20/20 are bringing the payments, retail and financial services industries together. This technology convergence is happening in a number of different areas throughout the payments ecosystem: at the cash register, in bank branches, on the web, and even in consumers’ wallets with traditional debit and credit cards. What is driving this trend in the industry? Consumers’ appetite and demand for simplification, personalization and a more seamless user experience across channels. As a result, retailers, banks and payment brands are taking on digital transformations of all kinds enabled by emerging technologies such as mobile, cloud computing and APIs.
Banks and traditional financial institutions have traditionally been consumers of technology, not developers of technology but that mindset is changing. Banks are starting to have to think more and more like software companies and technology start-ups to keep pace with the digital demands of consumers and clients. I had a chance to chat with JP Nichols from the Bank Innovators Council about the interest from banks (both large and small) to roll up their sleeves, and work through ideation, design thinking and creative problem solving techniques to further innovation and combat disruption. Santander Bank’s hiring of Brad Leimer, is a perfect example of the digital transformation many banks are taking on. His attendance at Money20/20 will enable him to foster relationships with new partners, payments startups and even others outside the industry to help connect customers to the bank digitally.
While we’re starting to see more of this from banks, others companies at Money20/20 are also helping to more quickly facilitate digital transformation and ultimately bring payment networks, banks and retailers closer together. During Ryan McInerney’s keynote, Visa shared three key things they’re doing that will help build customer experiences that are intuitive, instinctive and inherently safe – reinventing the card through tokenization, moving services to the cloud, and opening up their payment network to developers. By tapping into the more than 10 billion connected devices in use today they’re able to build better relationships with customers. Startups are also changing the game for the industry. We’re hearing from companies like Plaid that are putting the tools in banks’ developers hands to integrate with their infrastructure to access financial data from credit and debit accounts.
Evolution in the Customer Experience
Ultimately, the core existence of Money20/20 has been around the rapid pace of innovation and learning from how others in the industry are evolving or helping others to evolve. Citi’s CEO of US Consumer and Commercial Banking openly discussed their plans for testing out a new operating model centered around its bank branch network. They’ve realized that branch banking today has changed and their clients expect more from their interactions with the bank through digital experiences. As a result, Citi is focusing on testing out a “branch of the future” in US test markets that brings in many aspects of the retail in-store experience with digital and mobile experiences.
On the merchant side, we got to experience first-hand Osama Bedier’s new startup Poynt, a payment platform for merchants, with a live demo. Not only are they getting backing from Chase Paymentech and Vantiv, the product also has partnered with a number of other products like Kabbage, Swarm, Vend, Bigcommerce, and others. They’re challenging and redefining industry boundaries with their “smart terminal”. Poynt accepts magnetic stripe, EMV, NFC, Bluetooth and QR code payment technologies. They’ve also already incorporated Apple Pay, and other payment methods including chip-and-pin, mobile apps, and whatever else the future brings. Their demo really was one of the top highlights of the day (and probably the show).
We’re experiencing some exciting and adventurous times ahead and Money20/20 is here to showcase it all.
The Perficient team is back in Vegas for another year at Money20/20! Before I jump into discussing a couple of the key themes from the first day of sessions, let me just say that the Money20/20 picked up right where they left off with last year’s show and has added some nice new touches of “flair”. As usual, conference attendees are immersed in branding from all of the top sponsors and the Money20/20 logo is EVERYWHERE you look. In addition to the nice big screens with video footage of the panel discussion, they’re now showing a live broadcast of several of the panel sessions on big screen TVs outside the rooms for people to watch. Several of the track sessions have been full or standing room only so this is a great way for others to still get to see and hear what all the buzz is about. Everyone seemed to be pretty excited about the Hackathon too. Now onto the good stuff…
There were several key themes and buzzwords we heard repeatedly throughout Sunday’s sessions:
1. Governance & Education – Virtual, digital and cryptocurrency…whatever you want to call it, the topic of how consumers viewed it, how financial institutions were handling it, and innovative products built on it was predominant during many of the sessions so far at Money20/20. So why was this brought up so much the first day? There are so many unknowns around it being a regulated and secure form of payment yet we’re seeing tons of new innovative products and payment systems that accept it or are built on it. The consensus was that there needed to be more standards around electronic money and cryptocurrencies like Bitcoin before it will ever reach critical mass. Simply put, TD Bank’s Hisham Salama said, “card-based payments will prevail until new regulations exist around digital currencies to protect consumers.” This form of payment is not backed by the government or insured by the FDIC. Eric Goldberg, Senior Council for the CFPB, was a panelist on the session, “Accelerated Innovation: Balancing Innovation and Regulation” and echoed this concern. The CFPB was attending Money20/20 to learn from what others are saying and doing in payments so they can better advise the industry on regulations intended to protect consumers.
In fact, the CFPB recently issued a statement warning consumers about the concerns and potential issues with virtual currency. Here’s a quote from the statement:
In a nutshell, while virtual currencies offer the potential for innovation, a lot of big issues have yet to be resolved – some of which are critical. If you are interested in using or buying virtual currencies, you should be aware of the associated risks.
At one point during the session with the CFPB, an attendee asked the question why wasn’t there just one governing body to help standardize and advise financial services, payment companies and consumers on how to deal with electronic money and new forms of payment like cryptocurrency. I think all the panelists looked at each other and there were several seconds of silence before one of them jumped in to try to tackle the question. The answer is – there isn’t. And the better question in response may be – will there ever be? In a perfect world, I”m sure everyone would love for this to be the case. It would make everyone’s jobs easier and the future of payments innovation much more predictable. However, that’s not the case in the current environment so as companies look to better balance innovation and regulation – they’re focusing on several key areas: security and privacy, the user experience, understanding the customer value chain and leveraging tools and technologies (like Apple Pay) to extend payments not disintermediate them for consumers.
2. Collaboration is Key – During the panel, “Managing AML and OFAC Risk in a Dynamic Regulatory Environment” led by PwC’s Daniel Tannebaum, it was apparent that the word collaboration would be the predominant theme during this session. Joined by FinCEN’s Jamal El-Hindi, panelists from PayPal and AMEX offered some great advice for Money20/20 attendees. First, Rick Small from AMEX talked about engaging with the business early and often when it came to developing and launching new financial services and payment products. Tone, implementing a risk-based approach and clearly understood the organization’s risk appetite are three critical aspects of managing AML and OFAC compliance.
In talking with the Perficient team after this session, one of my teammates commented that compliance isn’t compensated like the business is, and as a result is often a challenge integrating this aspect to make ends meet and help the business grow. However, AMEX’s Small commented on how compliance can add value and reduce risk for an organization. Making sure the proper controls and requirements are in place helps minimize cost inefficiencies up-front and can drastically reduce the risk of penalties, fines and reputational risk for an organization.
PayPal’s Gene Truono talked about businesses needing a cross-functional approach to compliance with collaboration from fraud, technology, product development and delivery channel teams. Without this having a “culture of compliance” will be nearly impossible. Panelists across the board also encouraged Money20/20 attendees to reach out to not only Federal regulators but state to help them better understand and interpret the dynamic regulatory environment and plan for the future. In reference to managing regulatory compliance, Truono jokingly said, “Can’t we get an app for that?” Among the thousands of personal finance management and payments apps added daily, I don’t think there is one available yet in the iTunes Store for regulatory compliance. Who wants to jump on developing that one?
3. Policies and Procedures – Right now security, privacy and fraud are probably the biggest concerns in the financial services industry today. The almost daily news of data breaches and reports of cybercrimes has made it a tough challenge to tackle for financial institutions and payment providers. From having the latest analytics tools to the proper controls in place, businesses are constantly having to find new ways to stay one step ahead of fraudsters. While there’s no “one size fits all” solution for global fraud and AML, panelist urged Money20/20 attendees to take a good hard look at several key areas within their business.
One, businesses need to have sound AML and KYC policies and reporting procedures in place to monitor and prevent fraud and money laundering. These areas continue to consistently be an ongoing area of investment for the larger financial institutions and has trickled down into smaller businesses and even into how firms are dealing with controlling cryptocurrency. If you happen to be a target or a subject of a federal investigation, you’d better hope you’ve crossed your t’s and dotted your i’s when it comes to the adequacy and effectiveness of SAR content and sanctions screenings.
Two, the industry as a whole needs to do a better job of knowing who their customers are and how personal financial data sharing can aid and streamline efforts. We’re starting to see financial institutions come together to back things like the Swift KYC Registry initiative. The industry needs to see more of these kinds of standards and utilities around compliance to help lessen the burden of dealing with the cost of compliance and using it as a competitive advantage. As several of the sessions mentioned, “smart” regulations can help foster payments and fintech innovation. They’re also designed to help keep a level playing field in the industry – most firms are just stuck in the unfortunate position of just trying to keep up. The shift towards a new operating model (one that harnesses regulations as opposed to just coping with them) in financial services is indeed a concern. As Money20/20 has proven, the pace at which payments and financial services innovation is occurring is rapid. Often times this means turning to the experts outside your doors – after all, that’s what we’re here for and there’s no shame in that.
We’re looking forward to Day 2 at Money20/20 and the shift in discussion around innovation and what’s ahead in payments. Don’t forget to stop by and see the Perficient team in booth #104 and continue the bank risk and regulatory compliance discussion with our experts!
The role of corporate finance in financial services firms has evolved as the demands for balancing growth, regulatory compliance and risk management become increasingly important. According to CFO Magazine and an AlixPartners survey, 71 percent of finance executives polled said their companies need to have access to more robust business information. What’s driving this demand? Firms must be able to improve visibility, insight and control over financial performance, and this can be done through technology-enabled transformation initiatives.
Going forward, successful financial stewardship and the corporate finance function for organizations will require new strategies and ways of thinking about:
In our finance transformation webinar on Wednesday, Sanjay Balan, a finance and accounting expert for Perficient’s financial services practice, will guide you through the strategic vision and components of successful finance transformation projects that will help your enterprise to: identify gains in operational efficiency, improve forecasting and reporting, reduce risk, and optimize the strategic functions of the finance organization.
To register for the webinar, click here.
Improve Efficiency, Compliance and Productivity Through Finance Transformation in Financial Services
Wednesday, October 29, 2014