EMIR REFIT – Trade Reporting

Wes Cude Regulation

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

Wes Cude Non-Financial Risk Management

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

Wes Cude Regulation

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).

Sanctions and KYC following the Russian Invasion of Ukraine

New Link Editor Anti-Financial Crime

“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

New Link Editor Anti-Financial Crime

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

New Link Editor Non-Financial Risk Management

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

New Link Editor Anti-Financial Crime

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. …