Further to the introduction of the European Market Infrastructure Regulation (EMIR) in 2012 and subsequent revisions in 2015 and 2017, the REFIT program (Regulatory Fitness and Performance Program) was instigated. The purpose of the REFIT for Trade Reporting, which commenced in 2019, has been to review the issues identified in the years since reporting obligations were introduced and to use these findings to enhance the accuracy of Trade Reporting, through improved data quality and industry standardisation.
Farage and Debanking Update
In this article we will try to unravel the key developments and assess their potential impacts on banks and financial institutions. We believe this is more than a storm in a teacup and firms will need to follow developments closely over the coming months, as well as take a long hard look at their current policies and procedures – and previous debanking decisions. It is important to note that this is not just about account closures: firms need to also take a close look at how on-boarding decisions are made.
Summary of the PSD3 Proposal
On 28 June 2023, the European Commission published a proposed legislative package that seeks to modernise and harmonise the existing regulatory framework for electronic payments throughout the European Union (EU) and European Economic Area (EEA), currently regulated by the Second Payment Service Directive (PSD2).
When Reputational Risk Management Causes Reputational Harm
The current media interest in the banking arrangements of Nigel Farage has highlighted some of the challenges faced by financial institutions when deciding which new customers to take on and which customers to keep.
Client Transitions: Navigating Tricky Waters
Navigating the tricky waters of migrating clients from one platform to another is a difficult yet frequent undertaking in Financial Services.
Sanctions and KYC following the Russian Invasion of Ukraine
“Businesses need to take basic steps to investigate their own potential links to sanctioned Russian businesses and individuals, or else face the potential for what should be an avoidable worst-case scenario…You are supposed to be screening absolutely everyone you do business with — suppliers, customers and partners. This is a strict liability, and it doesn’t matter if you didn’t know.” …
The FinCEN Files – Our Perspective
Over 2,100 Suspicious Activity Reports (‘SARs’) that were filed with the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) between 2011 and 2017, have been leaked to BuzzFeed News and investigated by a team of reporters from the International Consortium of Investigative Journalists (‘ICIJ’). There has been no question regarding the authenticity of the documents. The ICIJ is drip-feeding the results …
Assessing the Effectiveness of a Compliance Function
Whilst many firms may think that their Compliance arrangements are purring along just nicely thank-you-very-much, there are not many who can say – never mind actually evidence – that their Compliance function is doing everything just right. Compliance departments, in this very changeable world, are not immune to the need to grow, develop, and improve. Senior management will want to …
Transforming CLM Operations
Whilst most of the Client Lifecycle Management (CLM) commentary out there touts technology, automation, robotics and artificial intelligence as the answer to all of your CLM and client on-boarding challenges, New Link Consulting takes the view that many firms should be spending their time fixing some of the more fundamental challenges of CLM before investing in the newest, shiny thing. …
Transformation from back to front office
Customers of banks have new expectations, sometimes driven by their own technology. This article discusses the pressure on banks to change their technology quickly.
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