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. …

What is SFTR?

New Link Editor Regulation

Following the financial crisis, both securities lending and repurchase transactions came under increased scrutiny as they were perceived to have contributed to the build-up of hidden leverage in the market. Regulators sought to introduce Securities Financing Transaction Regulation (SFTR), covering three key requirements: transaction reporting, disclosure obligations and collateral reuse obligations. SFTR is a sweeping mandatory change for the securities …

Simon Hirtenstein Speaks at Global Custodian Forum

New Link Editor Project Management

After the Global Custodian Forum, we are delighted to share with you comments from Simon Hirtenstein, our Asset Servicing Practice Lead. “I attended and spoke at the Global Custodian Forum in the salubrious surroundings of Banking Hall. First of all, many thanks to the event organisers and venue staff who put on a fantastic event. The day was full of …

The Volcker Rule

New Link Editor Front Office

An exploration of the potential modifications the OCC will make to the Volcker Rule to reduce the burden on banks whilst still serving its original purpose.