Another year has gone by and the FCA’s combined Business Plan and Risk Outlook has been released… So what’s new and what does it mean for your firm?
Our briefing walked through the key messages of the document and took a look back at 2015’s release. We also explored what you might need to be doing differently in the year ahead.
The European Banking Authority are proposing to change fundamentally the prudential landscape for investment firms. In this briefing we looked at these proposals for strategic context around the update to your 2016 ICAAP.
Spotting the banana skins - avoiding FCA enforcement through better complianc...Bovill
Bovill - the UK financial services regulatory consultancy - runs regular briefings. These are the slides from the May briefing on FCA enforcement and compliance oversight. For more information visit www.bovill.com.
Further information on the event is below:
The FCA’s Risk Outlook last month sent a strong signal that the responsibility of compliance officers goes beyond ticking boxes. And enforcement action shows that increasingly individuals are held accountable.
But what does this mean practically for day to day governance and oversight? One way to spot the banana skins is to understand who’s slipped on them before.
The FCA has recently imposed significant personal fines on compliance officers and other approved persons for:
• Inadequate oversight of the implementation of a firm’s policies and procedures
• Failure to disclose a potential conflict of interest
• Failure to recognise the regulatory significance and have sufficient oversight of the firm’s overseas activities.
Bovill’s briefing explored effective oversight.
We looked at the FCA’s reasons for imposing these fines, and suggested ways of making sure your firm has sufficient oversight of its business –
helping you spot the banana skins before you slip up.
Financial institutions around the world need to get their collateral management processes ready for the challenges ahead. The goal is to establish robust collateral management. But what is robust collateral management - and how can institutions get there?
Find out even more in our associated whitepaper, available for free on our website: http://foxeye.me/p6c3j
We are also hosting a series of associated webinars to introduce this topic in an interactive session. You may register for free on our website: http://foxeye.me/ttuye
The European Banking Authority (EBA) launched a consultation on its draft Regulatory Technical Standards on assessment methodology for internal ratings-based approach. These draft RTS are a key component of the EBA's work to ensure consistency in models outputs and comparability of risk-weighted exposures and will contribute to harmonize the supervisory assessment methodology across all EU Member States. The consultation runs until 12 March 2015.
Another year has gone by and the FCA’s combined Business Plan and Risk Outlook has been released… So what’s new and what does it mean for your firm?
Our briefing walked through the key messages of the document and took a look back at 2015’s release. We also explored what you might need to be doing differently in the year ahead.
The European Banking Authority are proposing to change fundamentally the prudential landscape for investment firms. In this briefing we looked at these proposals for strategic context around the update to your 2016 ICAAP.
Spotting the banana skins - avoiding FCA enforcement through better complianc...Bovill
Bovill - the UK financial services regulatory consultancy - runs regular briefings. These are the slides from the May briefing on FCA enforcement and compliance oversight. For more information visit www.bovill.com.
Further information on the event is below:
The FCA’s Risk Outlook last month sent a strong signal that the responsibility of compliance officers goes beyond ticking boxes. And enforcement action shows that increasingly individuals are held accountable.
But what does this mean practically for day to day governance and oversight? One way to spot the banana skins is to understand who’s slipped on them before.
The FCA has recently imposed significant personal fines on compliance officers and other approved persons for:
• Inadequate oversight of the implementation of a firm’s policies and procedures
• Failure to disclose a potential conflict of interest
• Failure to recognise the regulatory significance and have sufficient oversight of the firm’s overseas activities.
Bovill’s briefing explored effective oversight.
We looked at the FCA’s reasons for imposing these fines, and suggested ways of making sure your firm has sufficient oversight of its business –
helping you spot the banana skins before you slip up.
Financial institutions around the world need to get their collateral management processes ready for the challenges ahead. The goal is to establish robust collateral management. But what is robust collateral management - and how can institutions get there?
Find out even more in our associated whitepaper, available for free on our website: http://foxeye.me/p6c3j
We are also hosting a series of associated webinars to introduce this topic in an interactive session. You may register for free on our website: http://foxeye.me/ttuye
The European Banking Authority (EBA) launched a consultation on its draft Regulatory Technical Standards on assessment methodology for internal ratings-based approach. These draft RTS are a key component of the EBA's work to ensure consistency in models outputs and comparability of risk-weighted exposures and will contribute to harmonize the supervisory assessment methodology across all EU Member States. The consultation runs until 12 March 2015.
Operational Risk Management Under Basel II & Basel IIIEneni Oduwole
In this introductory presentation on the subject, salient features that changed in approaches adopted for Operational Risk Management under Basel I and Basel I were highlighted.
The SEC & FINRA released their priorities for 2016 examinations. Asset management firms need to review + update their policies, procedures and business activities to reflect both sets of priorities so they can strengthen business practices and prepare for potential exams.
Operational Risk Management under BASEL eraTreat Risk
Operational risk have always ignored by Banks as they thought Credit and market risks can cause catastrophe. But history of misfortunes taught us different lessons. Controls and internal audit have long been construed as guard till BASEL II dictates forced banks to look with insight. Understand the dimension of ORM in this presentation.
Risk management is an integral part of business management. This set of principles was developed by the industry for the industry. They have been drafted to make them so practical that they will resonate with any financial organization.
Operational Risk Management Under Basel II & Basel IIIEneni Oduwole
In this introductory presentation on the subject, salient features that changed in approaches adopted for Operational Risk Management under Basel I and Basel I were highlighted.
The SEC & FINRA released their priorities for 2016 examinations. Asset management firms need to review + update their policies, procedures and business activities to reflect both sets of priorities so they can strengthen business practices and prepare for potential exams.
Operational Risk Management under BASEL eraTreat Risk
Operational risk have always ignored by Banks as they thought Credit and market risks can cause catastrophe. But history of misfortunes taught us different lessons. Controls and internal audit have long been construed as guard till BASEL II dictates forced banks to look with insight. Understand the dimension of ORM in this presentation.
Risk management is an integral part of business management. This set of principles was developed by the industry for the industry. They have been drafted to make them so practical that they will resonate with any financial organization.
Captive Review Dublin Report 2016: Outsourcing under the Solvency II RegimeMatheson Law Firm
Darren Maher discusses the Solvency II Directive which came into force in Ireland on 1 January 2016, and how it impacts captive insurers who often rely heavily on outsourcing.
Forward-Looking Practices in Wealth ManagementCognizant
To keep up with growing regulations in wealth management sector, firms need to future-proof their operations with a robust risk-control system and transparent trading practices.
Vendor Management Best Practices: Is Your Program Up to Par?EDR
Vendor Management Best Practices: Is Your Program Up to Par?
Webinar presented by Scott Roller, former head of vendor management at Citigroup
August 12, 2015
Among the top challenges lenders face today is the need to meet higher expectations set by the OCC and the Federal Reserve governing the use of third-party vendors. While the guidelines were released over a year ago, there is still confusion about what institutions should be doing.
One thing, however, is certain. Effective vendor management takes resources, and many institutions are finding it necessary to add staff and/or technology to help with the cause, particularly smaller institutions. The regulators have made it clear, vendor management is not just a one-time assessment, but is an ongoing process, and monitoring vendors long term is as important as the initial due diligence.
EDR is pleased to host a webinar on this timely topic on Wednesday, August 12, 2015 at 2:00 p.m. EST. Scott Roller, former head of vendor management at Citigroup, will provide clarity on the new regulations and help break down regulator expectations into easy-to-understand terms. Roller will explore key dimensions that attendees can use as the foundation for building out their own robust vendor management oversight program, from initial vendor risk classification all the way through ensuring adequate executive engagement in vendor management.
Attendees will learn best practices for satisfying regulators with this educational workshop, including answers to the following:
• What does the latest regulatory guidance on vendor management require?
• What are the biggest headaches banks are facing in complying with them?
• What advice is recommended for smaller banks struggling with limited manpower/resources?
• What are bank examiners looking for during audits?
• What are the latest best practices for policies and procedures?
• How are banks coping with the need to track and monitor vendors?
• What are the most common shortcomings that audits reveal?
How to Prepare Your Firm for a Visit from the SRALegl
The SRA regularly visit law firms to monitor their compliance with AML regulations. In this session, we cover the areas that will put you ahead of the game should you receive notice that your firm will receive a visit.
Visit https://legl.com/events/webinar-how-to-prepare-your-firm-for-a-visit-from-the-sra-view/ to watch the full webinar.
Presentation to Ukraine Commodity Market Development Conference
The author of the presentation: Kevin Piccoli, Commodity Futures Trading Commission (US)
Outsourcing Strategy Risks Outsourcing strategy is the process of .pdfaparnaagenciestvm
Outsourcing Strategy Risks
Outsourcing strategy is the process of determining whether or not to outsource and, if so, what
to outsource.
Outsourcing Selection Risks
Outsourcing selection is the process of finding and evaluating potential outsourcing partners.
Outsourcing Implementation Risks
Outsourcing implementation is where the relationship between outsourcing partners is defined
and established.
Outsourcing Management Risks
Outsourcing management is the monitoring and evolution of the ongoing relationship.
Future Trends in Outsourcing
The Supply Chain Consortium will examine more of the risks of outsourcing within specific
levels of the supply chain in the future. Already, the consortium has administered surveys to its
member companies on the outsourcing of transportation and distribution center (DC) operations.
Among the findings:
The use of service providers to perform operational functions presents various risks to financial
institutions. Some risks are inherent to the outsourced activity itself, whereas others are
introduced with the involvement of a service provider. If not managed effectively, the use of
service providers may expose financial institutions to risks that can result in regulatory action,
financial loss, litigation, and loss of reputation. Financial institutions should consider the
following risks before entering into and while managing outsourcing arrangements.
• Compliance risks arise when the services, products, or activities of a service provider fail to
comply with applicable U.S. laws and regulations.
• Concentration risks arise when outsourced services or products are provided by a limited
number of service providers or are concentrated in limited geographic locations.
• Reputational risks arise when actions or poor performance of a service provider causes the
public to form a negative opinion about a financial institution.
Country risks arise when a financial institution engages a foreign-based service provider,
exposing the institution to possible economic, social, and political conditions and events from the
country where the provider is located.
• Operational risks arise when a service provider exposes a financial institution to losses due to
inadequate or failed internal processes or systems or from external events and human error.
• Legal risks arise when a service provider exposes a financial institution to legal expenses and
possible lawsuits.
who should be held liable for any breaches that occur
The use of service providers does not relieve a financial institution\'s board of directors and
senior management of their responsibility to ensure that outsourced activities are conducted in a
safe-and-sound manner and in compliance with applicable laws and regulations. Policies
governing the use of service providers should be established and approved by the board of
directors, or an executive committee of the board. These policies should establish a service
provider risk management program that addresses risk a.
Presentation by Bachir El Nakib at The International Conference on:
Combating Money Laundering and Terrorist Financing"(AML/CFT)
27th – 28th of April 2011, Coral Beach Hotel, Beirut – Lebanon
FATF's June 2013 Guidance Note on a Risk Based Approach to Implementing AML/C...Louise Malady
Understanding and using FATF's June 2013 Guidance note of a Risk Based Approach to Implementing AML/CFT Measures for mobile money and other new payment methods
Digital Commerce Lecture for Advanced Digital & Social Media Strategy at UCLA...Valters Lauzums
E-commerce in 2024 is characterized by a dynamic blend of opportunities and significant challenges. Supply chain disruptions and inventory shortages are critical issues, leading to increased shipping delays and rising costs, which impact timely delivery and squeeze profit margins. Efficient logistics management is essential, yet it is often hampered by these external factors. Payment processing, while needing to ensure security and user convenience, grapples with preventing fraud and integrating diverse payment methods, adding another layer of complexity. Furthermore, fulfillment operations require a streamlined approach to handle volume spikes and maintain accuracy in order picking, packing, and shipping, all while meeting customers' heightened expectations for faster delivery times.
Amid these operational challenges, customer data has emerged as an important strategy. By focusing on personalization and enhancing customer experience from historical behavior, businesses can deliver improved website and brand experienced, better product recommendations, optimal promotions, and content to meet individual preferences. Better data analytics can also help in effectively creating marketing campaigns, improving customer retention, and driving product development and inventory management.
Innovative formats such as social commerce and live shopping are beginning to impact the digital commerce landscape, offering new ways to engage with customers and drive sales, and may provide opportunity for brands that have been priced out or seen a downturn with post-pandemic shopping behavior. Social commerce integrates shopping experiences directly into social media platforms, tapping into the massive user bases of these networks to increase reach and engagement. Live shopping, on the other hand, combines entertainment and real-time interaction, providing a dynamic platform for showcasing products and encouraging immediate purchases. These innovations not only enhance customer engagement but also provide valuable data for businesses to refine their strategies and deliver superior shopping experiences.
The e-commerce sector is evolving rapidly, and businesses that effectively manage operational challenges and implement innovative strategies are best positioned for long-term success.
In this presentation, Danny Leibrandt explains the impact of AI on SEO and what Google has been doing about it. Learn how to take your SEO game to the next level and win over Google with his new strategy anyone can use. Get actionable steps to rank your name, your business, and your clients on Google - the right way.
Key Takeaways:
1. Real content is king
2. Find ways to show EEAT
3. Repurpose across all platforms
Mastering Local SEO for Service Businesses in the AI Era is tailored specifically for local service providers like plumbers, dentists, and others seeking to dominate their local search landscape. This session delves into leveraging AI advancements to enhance your online visibility and search rankings through the Content Factory model, designed for creating high-impact, SEO-driven content. Discover the Dollar-a-Day advertising strategy, a cost-effective approach to boost your local SEO efforts and attract more customers with minimal investment. Gain practical insights on optimizing your online presence to meet the specific needs of local service seekers, ensuring your business not only appears but stands out in local searches. This concise, action-oriented workshop is your roadmap to navigating the complexities of digital marketing in the AI age, driving more leads, conversions, and ultimately, success for your local service business.
Key Takeaways:
Embrace AI for Local SEO: Learn to harness the power of AI technologies to optimize your website and content for local search. Understand the pivotal role AI plays in analyzing search trends and consumer behavior, enabling you to tailor your SEO strategies to meet the specific demands of your target local audience. Leverage the Content Factory Model: Discover the step-by-step process of creating SEO-optimized content at scale. This approach ensures a steady stream of high-quality content that engages local customers and boosts your search rankings. Get an action guide on implementing this model, complete with templates and scheduling strategies to maintain a consistent online presence. Maximize ROI with Dollar-a-Day Advertising: Dive into the cost-effective Dollar-a-Day advertising strategy that amplifies your visibility in local searches without breaking the bank. Learn how to strategically allocate your budget across platforms to target potential local customers effectively. The session includes an action guide on setting up, monitoring, and optimizing your ad campaigns to ensure maximum impact with minimal investment.
Mastering Multi-Touchpoint Content Strategy: Navigate Fragmented User JourneysSearch Engine Journal
Digital platforms are constantly multiplying, and with that, user engagement is becoming more intricate and fragmented.
So how do you effectively navigate distributing and tailoring your content across these various touchpoints?
Watch this webinar as we dive into the evolving landscape of content strategy tailored for today's fragmented user journeys. Understanding how to deliver your content to your users is more crucial than ever, and we’ll provide actionable tips for navigating these intricate challenges.
You’ll learn:
- How today’s users engage with content across various channels and devices.
- The latest methodologies for identifying and addressing content gaps to keep your content strategy proactive and relevant.
- What digital shelf space is and how your content strategy needs to pivot.
With Wayne Cichanski, we’ll explore innovative strategies to map out and meet the diverse needs of your audience, ensuring every piece of content resonates and connects, regardless of where or how it is consumed.
The session includes a brief history of the evolution of search before diving into the roles technology, content, and links play in developing a powerful SEO strategy in a world of Generative AI and social search. Discover how to optimize for TikTok searches, Google's Gemini, and Search Generative Experience while developing a powerful arsenal of tools and templates to help maximize the effectiveness of your SEO initiatives.
Key Takeaways:
Understand how search engines work
Be able to find out where your users search
Know what is required for each discipline of SEO
Feel confident creating an SEO Plan
Confidently measure SEO performance
10 Video Ideas Any Business Can Make RIGHT NOW!
You'll never draw a blank again on what kind of video to make for your business. Go beyond the basic categories and truly reimagine a brand new advanced way to brainstorm video content creation. During this masterclass you'll be challenged to think creatively and outside of the box and view your videos through lenses you may have never thought of previously. It's guaranteed that you'll leave with more than 10 video ideas, but I like to under-promise and over-deliver. Don't miss this session.
Key Takeaways:
How to use the Video Matrix
How to use additional "Lenses"
Where to source original video ideas
Short video marketing has sweeped the nation and is the fastest way to build an online brand on social media in 2024. In this session you will learn:- What is short video marketing- Which platforms work best for your business- Content strategies that are on brand for your business- How to sell organically without paying for ads.
Most small businesses struggle to see marketing results. In this session, we will eliminate any confusion about what to do next, solving your marketing problems so your business can thrive. You’ll learn how to create a foundational marketing OS (operating system) based on neuroscience and backed by real-world results. You’ll be taught how to develop deep customer connections, and how to have your CRM dynamically segment and sell at any stage in the customer’s journey. By the end of the session, you’ll remove confusion and chaos and replace it with clarity and confidence for long-term marketing success.
Key Takeaways:
• Uncover the power of a foundational marketing system that dynamically communicates with prospects and customers on autopilot.
• Harness neuroscience and Tribal Alignment to transform your communication strategies, turning potential clients into fans and those fans into loyal customers.
• Discover the art of automated segmentation, pinpointing your most lucrative customers and identifying the optimal moments for successful conversions.
• Streamline your business with a content production plan that eliminates guesswork, wasted time, and money.
Most small businesses struggle to see marketing results. In this session, we will eliminate any confusion about what to do next, solving your marketing problems so your business can thrive. You’ll learn how to create a foundational marketing OS (operating system) based on neuroscience and backed by real-world results. You’ll be taught how to develop deep customer connections, and how to have your CRM dynamically segment and sell at any stage in the customer’s journey. By the end of the session, you’ll remove confusion and chaos and replace it with clarity and confidence for long-term marketing success.
Key Takeaways:
• Uncover the power of a foundational marketing system that dynamically communicates with prospects and customers on autopilot.
• Harness neuroscience and Tribal Alignment to transform your communication strategies, turning potential clients into fans and those fans into loyal customers.
• Discover the art of automated segmentation, pinpointing your most lucrative customers and identifying the optimal moments for successful conversions.
• Streamline your business with a content production plan that eliminates guesswork, wasted time, and money.
When most people in the industry talk about online or digital reputation management, what they're really saying is Google search and PPC. And it's usually reactive, left dealing with the aftermath of negative information published somewhere online. That's outdated. It leaves executives, organizations and other high-profile individuals at a high risk of a digital reputation attack that spans channels and tactics. But the tools needed to safeguard against an attack are more cybersecurity-oriented than most marketing and communications professionals can manage. Business leaders Leaders grasp the importance; 83% of executives place reputation in their top five areas of risk, yet only 23% are confident in their ability to address it. To succeed in 2024 and beyond, you need to turn online reputation on its axis and think like an attacker.
Key Takeaways:
- New framework for examining and safeguarding an online reputation
- Tools and techniques to keep you a step ahead
- Practical examples that demonstrate when to act, how to act and how to recover
Top 3 Ways to Align Sales and Marketing Teams for Rapid GrowthDemandbase
In this session, Demandbase’s Stephanie Quinn, Sr. Director of Integrated and Digital Marketing, Devin Rosenberg, Director of Sales, and Kevin Rooney, Senior Director of Sales Development will share how sales and marketing shapes their day-to-day and what key areas are needed for true alignment.
For too many years marketing and sales have operated in silos...while in some forward thinking companies, the two organizations work together to drive new opportunity development and revenue. This session will explore the lessons learned in that beautiful dance that can occur when marketing and sales work together...to drive new opportunity development, account expansion and customer satisfaction.
No, this is not a conversation about MQLs and SQLs. Instead we will focus on a framework that allows the two organizations to drive company success together.
Digital Money Maker Club – von Gunnar Kessler digital.focsh890
Title One is a comprehensive examination of the impact of digital technologies on
modern society. In a world where technology continues to advance rapidly, this article delves into the nuances and complexities of the digital age, exploring Its implications across various sectors and aspects of life.
Digital Money Maker Club – von Gunnar Kessler digital.
Bovill outsourcing bcp and client money and assets 16 aug16
1. MAS’ Outsourcing Guidelines and Consultation
Paper on Customer’s Moneys and Assets
Bovill Briefing
August 2016
2. Asia Regulatory Radar – August 2016
MiFID II
Asset Mgt and
Capital Market
vulnerabilities
Asia Region
Funds
Passport
FAIR
Framework
OTC
Derivatives
Market Abuse
Investigations
Basel III
Liquidity
Rules
Regulatory
Safeguards for
Investors
Short
Position
Reporting
Suitability
Requirement
Central
Depository
System
REITS
Insurance
Remuneration
Market Risk
Capital
Requirements
Code on Take-
Overs and
Mergers
SFC Products
Handbook
Principles of
Responsible
Ownership
AML/CFT
Internal
Controls
Supervisory
Policy
Manual
FinTech
OTC
Derivatives
AIFMD Non-
EEA AIFM
Passports
Crowd
funding
Resolution
regime
Market
Misconduct
Regime
Resolution
Regime
Professional
Investor
Regime
Suitability
Requirement
Interest Rate
Risk
Requirements
Fund
Authorisation
Cyber
Security
Listing
Regulation
Outsourcing
Common
Reporting
Standards
Protection of
Customer
Money and
Assets
Cyber
Crime
2
3. 3
Key highlights
Implementation of the New
Outsourcing Guidelines
• Self-assessment of existing
outsourcing arrangements by 27
October 2016
• Deficiencies to be rectified by 26
July 2017
Outsourcing Arrangement
Definition
• For an arrangement to be
outsourcing arrangement, it does
not need to be prohibitive or
costly to change the service
provider.
Material Outsourcing
Arrangement - Definition
• If an outsourcing arrangement
materially impacts an institution’s
regulatory compliance and risk
management ability, it is material
List of low-risk
Outsourcing Arrangements
• This list is removed on the basis
that every institution should make
its own assessment of the
materiality of an outsourcing
arrangement
Notification to MAS
• Requirement to notify MAS prior
to entering into a material
outsourcing arrangement
removed(!)
• Maintain Outsourcing Register
(MAS Template)
Due Diligence on Service
Providers
• Due diligence, monitoring and
control of outsourced services
• Political, legal, economic
assessment for overseas
outsourcing
4. 4
Outsourcing and non-outsourcing arrangements
MAS has provided additional examples to demonstrate which arrangements are
considered outsourcing and which are non-outsourcing arrangements
Outsourcing Arrangements:
White-labelling arrangements (for e.g., arrangements for trading and hedging
facilities)
Information systems hosting (for e.g., SaaS, PaaS, IaaS)
Compliance as a professional service
Support services related to archival and storage of data and records
5. 5
Outsourcing and non-outsourcing arrangements
Non-Outsourcing Arrangements:
X Services which MAS expects independent service providers to provide (e.g.
Maintenance of custody account with specified custodians or independent fund
valuation)
X Global financial messaging infrastructure, which are subject to regulatory
oversight (e.g. SWIFT)
X Acceptance of business by underwriting agents as they relate to principal-agent
relationship
6. 6
Outsourcing assessment
Is it an outsourcing
arrangement?
Definition
and Annex 1
MAS Outsourcing
Guidelines do not
apply
Conduct usual vendor
related due diligence
Is it a material
outsourcing?
Definition and Annex 2
Apply the guidelines and additional
requirements applicable to material
outsourcing under the guidelines
Additional requirements
imposed for material
outsourcing arrangements
Apply the guidelines commensurate
with the nature of risks and materiality
of the outsourcing arrangements
Risk-based approach for
non-material outsourcing
arrangements
No Yes
Yes No
8. 8
Questions to ask
Impact Factors/Questions
Financial How important is business activity that is being outsourced (e.g., in terms of contribution to
income and profit)?
Operating Costs Is the cost of the outsourcing as a proportion of total operating costs of the institution material?
Operating Costs Is the cost of outsourcing failure, which will require the institution to bring the outsourced activity
in-house or seek similar service from another service provider, as a proportion of total operating
costs of the institution material?
Concentration Risk Is the aggregate exposure to a particular service provider in cases where the institution
outsources various functions to the same service provider material?
Operations Would there be a material impact on the institutions ability to maintain appropriate internal
controls and meet regulatory requirements, if the service provider faces operational problems?
If the service provider fails to provide the service or encounters a breach of confidentiality or
security…
Financial impact Will there be a material impact on earnings, solvency, liquidity, funding and capital, and risk
profile?
Reputational Impact Will there be a material impact on the institution’s reputation and brand value, and ability to
achieve its business objectives, strategy and plans?
Customer impact Will there be a material impact on the institution’s customers?
Counterparty impact Will there be a material impact on the institution’s counterparties and the Singapore financial
market?
9. 9
Outsourcing risk management
Role of
Senior
Management
and Board
Cost/benefit
analysis +
aggregate
exposure
assessment
Outsourcing
Arrangements
Due Diligence
Service
provider
suitability
Monitoring and
Control of
Outsourcing
Arrangements
Documenting
and
recording
10. 10
MAS reminders
Board and Senior Management remain ultimately responsible for
implementing adequate outsourcing risk management framework
Delegate not abdicate!
Ensure that there is a robust risk management framework for
Outsourcing Arrangements
Outsourcing of all or substantially all of the risk management or internal
controls by an institution will be considered material outsourcing
arrangement (for e.g. internal audit, compliance, financial accounting
etc.)
Be ready to demonstrate compliance to MAS
11. 11
Importance of Business Continuity Management
• Increased dependence on technology
• ‘Know Your Service Provider’ – BCP
requirements and joint testing
• Interdependence risks and Cloud services
13. Why it’s so important
2007 Present
day
Global
financial
crisis
Sept 2008
Lehman files
for bankruptcy
March 2012
World
Spreads
bankruptcy
Oct 2011
MF Global
bankruptcy
Sept 2013
Aberdeen
fined (eqv
S$13m)
July 2016
MAS consultation
on enhancements
to Protection of
Customer’s
Moneys and
Assets
Sept 2011
Towry fined
(eqv S$862k)
Sept 2012
Blackrock
fined (eqv
S$16.6m)
June 2010
JP Morgan
fined (eqv
S$58m)
Jan 2011
Barclays
Capital fined
(eqv S$1.8m)
March 2011
ActivTrades
fined (eqv
S$148k)
Jan 2012
MF Global
Singapore
Liquidated
14. 14
Definition of customer’s moneys
• Current rules only cover money received from or on
account of a customer
• Proposal to include contractual rights arising from
transactions entered into on behalf of or with a customer
Rule ref: LCB part 15. (2)
15. 15
Due diligence on banks
• Proposal to introduce a DD requirement on banks who
maintain the customer’s money account
• Periodic assessment of diversification
• Periodic review of due diligence on bank
16. 16
Appointing a custodian
• Selecting – remember diversification is important
• Appointing
• Periodically reviewing
• Due diligence is key!
• Don’t just rely on one source of information
17. 17
Acknowledgement letters – from FIs
Extension of the Acknowledgement Letter
to overseas financial institutions
Need to remember to review and update
periodically
18. 18
Recovery [and Resolution] Packs
Need to introduce information systems and controls to set out:
Location of customer’s moneys and assets
How assets are held, identity of all depositories
Type of segregation at all levels of the holding chain
Applicable rules (where overseas)
Outstanding loans of customer’s securities
19. 19
Computations and reconciliations
Daily computation requirement extended to all licensees, not just futures
or leveraged FX traders
Will require at least daily computation of total amount of moneys and
assets deposited, for all instruments
Rule ref: LCB part 37
20. 20
Re-hypothecation and other use
Currently risk disclosure and consent is required when lending
customer’s securities
Proposal to extend this to situations when licensee
- Mortgages
- Charges
- Pledges
- Hypothecates
their customer’s assets
21. 21
Other areas
Customer Disclosure
Prompt response to request for statement of account from customer
Dis-application of Reg 16(1)(b), which allows the customer to direct
which account to use
Application to banks:
- Current rules also apply to banks
- Proposal to dis-apply Money Rules
22. 22
Takeaways
As always – the creation and retention of records is paramount
Increased operational demands
Ongoing review of existing controls and processes
IT requirements, governance arrangements, policies and procedures
