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Regulation Update: The Economic Crime and Corporate Transparency Act Receives Royal Assent

The ECCTA strengthens the UK’s efforts to combat economic crime via a wide-ranging suite of reforms. These include new and enhanced powers for Companies House to scrutinise information provided by companies and their directors.

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Risk Management

How to Successfully Navigate the Complex and Ever-Changing PEPs and Sanctions Landscape

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Justin Fitzpatrick

How to successfully Navigate the Complex and Ever-Changing PEPs and Sanctions Landscape

The Russian invasion of Ukraine in February 2022 led to an unprecedented number of new sanctions against individuals, groups, and entities.  But it was not only the scale of the sanctions, issued by multiple regulators, but the speed with which they came into force that created an extremely complex environment for financial institutions (FIs), who have been racing to keep pace ever since.

Similarly, identifying and managing Politically Exposed Persons (PEPs) is increasingly complex due with regulators amplifying the need for vigilance.  Importantly, the FCA is currently undertaking a review to assess how regulated businesses are complying with their legal and regulatory obligations regarding PEPs.

Major national and international events can quickly prompt revisions to PEPs and sanctions lists targeting countries, businesses, groups, and individuals, as well as the level of restrictions imposed on them. In August 2023 the UK government announced a range of new sanctions against Iranian individuals and entities, and following the recent attacks on Israel it’s conceivable that we will see a new raft of sanctions targeting groups such as Hamas and Hizbollah.

How have FI’s responded so far?

It turns out, the response has not been that great actually!  According to new research from SmartSearch only 36% of challenger banks have made changes to compliance procedures to screen for PEPs and sanctions since the start of the conflict in Ukraine. And whilst fairing a little better, 40% incumbent banks still have not taken additional precautions.  

Whilst failure to keep up with PEPs and sanctions changes can lead to inadvertently facilitating money laundering, fraudulent activity, and illegal transactions, it can also run the risk of substantial fines and severe reputational damage.  According to Fenergo, in 2022 alone FIs globally were penalised to the tune of $4.2 billion due to breaches of Anti-Money Laundering (AML) regulations. A 52% increase from 2021 which brings into stark relief the scale of the challenge facing financial institutions right now.

It is crucial for FIs to conduct thorough screening checks and due diligence through the customer lifecycle – from identifying and acquiring new customers, through verification and onboarding, to retaining customers and growing relationships.

But it’s not just the changing PEPs and sanctions lists that are tough to navigate, it is equally difficult to untangle the complex hierarchical structures surrounding them.  Increasingly complex corporate structures and fragmented ownership data obscure a complete view and prevent organisations from effectively assessing risk. Not only does this pose challenges to meeting regulatory requirements, but it also impacts the customer experience.

Time for some good news…

Digital solutions can help simplify the complex PEPs and sanctions landscape and make it easier to navigate.  Here’s how:

  • Automated screening - Realtime global coverage to pre-screen for political exposure, sanctions, and adverse media to ensure that your customers are not involved in any illegal or prohibited activities.
  • Graph data visualisation – Recognise the connections between directors, shareholders, and group companies up to the Ultimate Beneficial Owner and understand any risks associated with the people you do business with.
  • Identify verification – verify identify in real time with automated document verification and facial comparison technology.
  • Perpetual KYC- Event-based alert notifications of changes to watchlists, financial and credit information

The even better news…get smarter on PEPs and sanctions

SmartOnboard from FullCircl is the industry’s comprehensive compliance platform, accelerating customer screening while enabling FIs to better manage risk throughout the customer lifecycle.  Features include:

  • Customer onboarding checks: Onboard business customers up to 94% faster with automated KYC, AML, and credit checks.  
  • Ongoing screening: Screen customers at any time to ensure information reflects current circumstances when reviewing customer products or internal risk appetite.  
  • PEPs, sanctions, and adverse media: Get access to PEPs, Sanctions and Adverse Media with categories aligned to the latest FATF recommendations and a 70% reduction in false positives.  
  • Ownership and UBOs: Understand company ownership structures and beneficial owners to help improve customer onboarding, reduce risk, and meet regulatory requirements.  
  • Credit & Risk: Assess a customer’s creditworthiness and financial health. FullCircl provide credit reports, credit scores, and other critical financial indicators to help you evaluate the customer’s credit worthiness quickly.  
  • Monitoring: Event-based alerts notify you of any changes in critical financial information held on the companies in your watchlist.

Book a demo and find out how FullCircl can help you onboard customers faster and manage risks smarter.

Or, why not join FullCircl and our partners at ComplyAdvantage on 2nd November for our interactive webinar, and get prepared to tackle the PEPs challenge.  Join our expert panel as we discuss:

  • Why there isn’t a globally agreed definition for PEPs and the methodologies that can be used to define them.
  • How adopting a data-driven approach to deliver a more layered solution for PEP screening empowers risk-based decision-making.
  • Best practices to assess PEPs’ family members, known associates, businesses, and their transactional relationships.
  • How to investigate relationships and financial interactions to identify broader patterns of sanctions evasion and political corruption.
Current Affairs

Broker Challenges: Counting the Cost of Regulation

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Ashleigh Gwilliam

Broker Challenges: Counting the Cost of Regulation

The cost of regulation for insurance brokers, especially small independent firms, is at all-time high.

According to BIBA, direct regulatory costs for brokers are 40% higher than in 2019.  Overall direct and indirect costs are equal to 8.1% of fees and commissions, a burden twice as high as experienced by counterparts in other countries. Add to this rising inflation, a hard market, the limits insurers are putting on volumes, and the rising costs associated with HR, accounting, marketing, and IT, and it’s no surprise to hear that many brokers are exiting the market and stating disproportionate regulation as a primary reason.

This could be highly damaging for the sector, which is largely made up of smaller firms. Brokers arrange over £74 billion of insurance each year, which is 67% of general insurance business and 81% of all commercial insurance business in the UK. However, the number of independent brokers and agents in the UK has declined by 0.4% per year on average over the last five years.

Of course, regulation plays a vital role in maintaining a healthy insurance ecosystem, but it must be proportionate. Something BIBA pointed out at its annual conference in May when concerns were raised that red tape costs have increased exponentially for brokers in the past three years.  

BIBA urged the FCA to proceed with caution when considering the impact of regulation bearing in mind more than one in four employees in smaller firms are focused entirely on regulatory matters. BIBA CEO Graeme Trudgill reaffirmed this in his manifesto in July 2023, stating that smaller brokers are swamped by regulation and that the cost is prohibitive.  

Tackling the regulation challenge

The first challenge for brokers is simply staying on top of regulation and ever-changing compliance requirements. One look at BIBA’s regulation updates page, and it’s immediately clear just what a challenge this is, especially for smaller brokers.    

The Consumer Duty passed earlier this year sets a higher and clearer standard of protection, requiring brokers to put their customers’ needs first. Whilst this is great for industry confidence, it increases complexity for brokers as well as incurring the additional time and costs associated with fair value assessments. And with the Government’s Future Regulatory Framework rapidly taking shape following royal assent of the Financial Services & Markets Act in June, brokers can expect a raft of new reforms in the coming months and years.  It’s vital they can proactively understand and adhere to regulatory updates to avoid penalties, maintain their licences, and build trust with their clients.   

A data-driven approach means brokers will never be blindsided by significant changes to regulation. Likewise, access to real-time customer information and insights ensures brokers gain a holistic view of each customer's financial situation, group structure etc. and can be alerted to any risk profile changes that could impact their ability to achieve their compliance requirements.

It's also important for brokers to look for opportunities to drive growth to offset the cost of regulation. Acquiring new business and retaining clients are two of the most important aspects of sustainable growth for any insurance broker. By leveraging data-driven insights, brokers can identify new opportunities and build strong, long-term relationships that drive growth and revenue.  

Instead of counting the cost of regulation, brokers can drive growth when times are tough by taking a smarter approach.

The smartest way to tackle the cost of regulation and drive growth

Introducing SmartBroker™. SmartBroker™ is democratising customer intelligence for the independent broking sector by enabling brokers to identify new opportunities and build long-term relationships that drive growth and revenue by leveraging data-driven insights.​

Benefits of Smart Broker:

  • Prospect with precision​ - Gain a complete view of the markets that matter to you, segmented by the attributes of your most profitable customers.
  • Prepare better underwriting submissions​ - Leverage data to remove knowledge gaps and ensure you produce comprehensive submissions every time.
  • Data-driven insights to tailor outreach​ - Real-time news insights will give you the right things to say at the right time and help become a trusted advisor to your clients.
  • Increase client retention​ - Don’t get blindsided by significant changes to your client’s business and risk portfolio at renewal. Be alerted to changes, to help mitigate risks sooner.

FullCircl is proud to support many independent brokers, as well 9 of the top 10 UK brokers, 40 of the top 50.  

To find out how SmartBroker™ can support your business, speak with one of our insurance experts to arrange a demo, see pricing and get started.

Customer Due Diligence

How to create effective customer due diligence for banks and increase profitability

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Justin Fitzpatrick

How to create effective customer due diligence for banks and increase profitability

Onboarding is a crucial stage in every customer journey, and customer due diligence for banks is a vital component of the onboarding process. If due diligence is badly handled and too onerous, leaving potential customers frustrated by delays and complex requests, they may abandon onboarding, which means the bank loses a new revenue stream. And if it’s incomplete or inaccurate, the bank may onboard a customer who is a commercial and reputational liability, with the risk of heavy fines from regulators.  

Due diligence refers to all the essential checks that a bank must perform to confirm the identity and background of a potential or existing customer, and is a regulatory requirement to mitigate risks such as money laundering and financing terrorism. It typically involves collecting and verifying data about financial and business activities, and requires ongoing monitoring to identify changes in a customer’s risk profile.  

Effective due diligence for banks will promote customer lifetime value: it distinguishes good customers from bad ones, ensures compliance and operational efficiency, and creates a strong foundation for profitable and lasting relationships.  

Let’s explore the requirements for effective customer due diligence for banks and the challenges they face today, then show how the right technology can save time and provide the insights banks need to boost customer experience and make the right connections.  

Customer due diligence in practice

Customer due diligence is closely related to know your customer (KYC), as the aim is to create transparency and precision for every business relationship that a bank enters into. It should involve continuous monitoring over the lifetime of a customer so that banks can identify changes or red flags that might signal increased risk or illegal activity. The three main strands are:

Among other things, customer due diligence checks will involve thorough reviews of:

  • Identification documents
  • Information on business and financial history
  • Beneficial ownership structures  
  • Relevant public records  

At its core, customer due diligence for banks is necessary to ensure compliance with anti-money laundering regulations, which in turn help to combat the financing of terrorism. So, the twin regulatory objectives are AML and CFT.  

Challenges with customer due diligence for banks

Banks must onboard the right kind of customer and comply with ever-evolving regulations, but the customer due diligence process is often long and drawn out, off-putting for customers, and flawed. Surveys and statistics bear this out. For example, according to Oliver Wyman, it takes between 90 and 120 days to onboard a customer, while Thomson Reuters reported that 80% of corporates found it a poor experience.  

One of the main drawbacks when it comes to customer due diligence for banks, is the reliance on manual processing and outdated practices. Data is often unconnected and residing in silos, or it is fragmentary or no longer current. Lack of integration and poor data make it difficult to achieve a holistic and up-to-date view of customers. And if there are information gaps, then errors and oversights are inevitable. This is particularly the case when banks need to perform ongoing due diligence.  

As data sets grow, banks must process more information at speed. Delays and repetitive processes create a negative impression with customers, and customer due diligence for banks is usually the most data-intensive and time-consuming part of onboarding. When prospective customers find it too demanding, they may take their business to a competitor who can provide accelerated onboarding. Today, the speed of due diligence is a key measure of overall customer experience. However, because of the risk of fraud, banks must also ensure that speed is combined with precision and security.

So, what must banks do to meet these challenges and optimise speed, security, and overall customer experience? The answer is to digitise and automate the due diligence process.      

Boosting profitability with streamlined customer due diligence

The first step is to create a comprehensive digital strategy for onboarding and regulatory reporting and compliance. Piecemeal changes will not solve weaknesses in security or operational deficiencies, especially with the growing risk of financial crime, and any bank that is still using spreadsheets will always be compromised.  

According to Mckinsey, the onboarding experience is often overlooked in corporate banking. This is a mistake because it can have significant financial implications. Apart from the risk of losing a potential customer, a lengthy due diligence process will dent time-to-revenue. Banks must therefore improve their digital infrastructures to capitalise on the growing demand from corporates.  

As Mckinsey says: ‘Participating in this growth opportunity will depend on banks optimising their end-to-end onboarding experience for transaction banking customers.’ McKinsey adds that its own research reveals that half of all banks lack a technology solution for many onboarding processes.  

How FullCircl enhances customer due diligence for banks

FullCircl provides the focus and technology to turn customer due diligence for banks into a revenue generator. Thanks to automated KYC, AML and credit checks, you can strengthen security and onboard customers in a fraction of the time it normally takes. Costly and error-prone manual processing is eliminated, and you maintain a 360-degree view of customers to ensure ongoing compliance.  

See our guide for better customer onboarding and a book a demo to discover all FullCirl’s capabilities for banks.  

Risk Management

Discover our latest Summer product release

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Justin Fitzpatrick

Discover our latest Summer product release

We're excited to introduce you to our latest product release. This release includes integrating PEPs and Sanctions data, which brings a new dimension to risk management, enabling you to safeguard your business against potential threats effectively. The Experian Delphi Score upgrade delivers unparalleled credit risk assessments, empowering you to make confident lending decisions. With Experian data now available within our API, acquiring crucial data has never been more seamless.

More Engagement Signals: Improved monitoring solution

New credit and risk-based triggers provide alerts to changes in a customer's creditworthiness and risk profile. This proactive approach enables you to make informed decisions swiftly and mitigate potential risks.

ComplyAdvantage PEPs and Sanctions integration: Enhanced compliance and risk mitigation

Staying compliant with regulations is a paramount concern for Financial Institutes. With our latest product update, we have integrated ComplyAdvantage PEPs and Sanctions data to provide a powerful onboarding and risk management tool. Now, you can effectively screen individuals and entities against global sanctions lists and identify high-risk customers, ensuring your business stays one step ahead of potential risks.

1000s of sources contribute to the comprehensive global coverage of Sanctions, PEPs & Watchlists, resulting 70% reduction in false positives.

Experian Delphi Score upgrade: Better credit risk assessment

The Experian Delphi Score is renowned for its precision in assessing credit risk. The upgrade incorporates Experian's latest credit scoring advancements, providing even more accurate and insightful credit risk assessments. Allowing you to make informed decisions confidently, minimise risks, and optimise your lending processes.

Experian Credit data within our API: Seamless data integration

We’ve introduced Experian credit data within our API to streamline your acquisition and onboarding process. Seamlessly integrate up-to-date Experian datasets into your systems, applications, and workflows. The integration enhances your data-driven decision-making capabilities and saves precious data acquisition and processing time.

New API modules: Tailored for maximum efficiency

Recognising the needs of our clients, we have expanded our API offering with a range of new use-case-focused modules. Our API library now offers specific datasets that align perfectly with your business requirements to help acquire new business, accelerate onboarding, and keep customers for life. 

To explore our latest release, or learn more about our services, schedule a demo to see how these new features will empower your business through comprehensive data and actionable insights.

Client Onboarding

Rethinking customer onboarding strategies

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Lucy Huntley

Six top trends that are making banking compliance teams rethink customer onboarding strategies in 2023

Time-to-revenue is an increasingly key metric for banks, whether they be traditional, challenger or neo. But banks are operating in an incredibly fast-paced, complex, and rapidly evolving environment, which can have significant detrimental impacts on the speed and efficiency of corporate customer onboarding processes.

The equation is simple - the longer onboarding takes, the slower the time to revenue.

With McKinsey’s Global Banking Annual Review predicting that corporate customers sit at the heart of a predicted 9% increase in global banking revenues over the next two years, delivering a fast, efficient, and compliant customer onboarding process is more critical than ever before. Get it right, and banks can enjoy competitive differentiation, greater efficiency, and revenue growth.

But what does getting it right look like?

Here are 6 key trends impacting the evolution of customer onboarding strategies in 2023:

1 - Regulation

Regulators are tightening controls in an attempt to make it harder for criminals to find weak links in the defence mechanisms of banks. It’s a constantly evolving regulatory landscape that presents a huge drain on resources and expertise. But with huge fines and reputational damage at stake compliance is non-negotiable.

As AML and other regulatory frameworks tighten, customer onboarding strategies must also evolve so that they can adapt to developments. The risks of not doing so includes creating compliance gaps, increasing costs, and overburdened teams.

But banks must also balance this against customer experience…

2 - Customer experience

Complex onboarding processes for new corporate clients can take up to 100 days. This can lead to significant dissatisfaction and abandonment, which is costly – banks are literally losing millions every year due to poor onboarding experiences.

Corporate banking customers want a service that’s fast, efficient, and frictionless. KYC processes present the most significant bottleneck to achieving this. Onboarding delays and frustrations typically result from the vast amount of data and documentation banks require for compliance.

Customer onboarding strategies must therefore review how data is acquired, processed, verified, and risk assessed if they are to deliver the seamless experiences customers demand.

3 - Identity verification

In today’s global banking environment, identity verification is tougher than ever. Banks must access real-time identity information across a wide range of national, international and government data sources. In addition, that must undertake watchlist screening against both local and global sanctions, and politically exposed persons (PEPs).

When rethinking their customer onboarding strategies banks must ensure that their identity verification capabilities meet both regulatory requirements and customer expectations for speed and convenience, as well as ensuring they have the inbuilt agility to remain compliant as the geopolitical and regulatory landscape evolves.

4 - Understanding complex corporate structures

Increasingly complex corporate structures and fragmented ownership data obscure a complete view and prevent banking compliance teams from effectively assessing risk, which in turn creates more friction in the onboarding process.

Complex corporate structures, often by design, do not lend themselves to ease of analysis. Identifying who owns and exercises control is incredibly time consuming, expensive, and fraught with inaccuracies that expose banks to both regulatory and reputational risk.

Customer onboarding strategies that can map out and visualise corporate ownership will be able to manage risks in the most accurate and cost-effective way possible.

5 - Environmental, Social & Governance (ESG)

Banks are under pressure to expand customer due diligence (CDD) procedures to include risks posed by ESG factors when assessing prospective customers. Whilst the intersection of ESG, KYC and onboarding is new, integrating ESG into onboarding processes is now a necessity. ESG is increasingly part of the scope of regulatory activities, presents legal and reputational risks, and is a top agenda item for investors, customers, and the public-at-large.

As a bare minimum customer onboarding strategies need to be cognizant of customer ESG practices and how prospects manage the social and environmental risks those pose. But best practice moving forward would be to incorporate new abilities to include ESG specific risk factors based on a customer’s potential risk exposures including the nature of their industry, countries of operation, sources of funds/wealth, as well as proactive measures such as adverse media screening.

6 - Emerging payment fraud risks

Authorised push payment (APP) fraud is one of the fastest growing types of scams, one that has seen banks lose £145 million in the first half of 2023 alone. From 2024 a new Confirmation of Payee service will help banks ensure payee names and account details match before undertaking transactions, but in the meantime, advanced KYC verification methods during the onboarding process can help prevent fraudsters from entering the system

Accessing detailed financial and historical company intelligence (shareholders, group structure, ultimate beneficial owners and more) from verified and validated sources, contextualised and mapped ensures nothing is missed at any stage of the onboarding process. Likewise, identify key events like CCJs or Gazette notices immediately, by checking potential customers/merchants against global PEP and sanctions lists can help banks prevent payment fraud and keep bad actors out.

How FullCircl can help banks evolve next-generation customer onboarding strategies?

FullCircl is a game changer in onboarding acceleration.

It’s a Customer Lifecycle Intelligence (CLI) platform that allows banks to overlay policies and risk appetite across trigger changes in their customer base. It also uses automated data collection and checks and connects data points to expose potential risks across networks of people and businesses.

The overall impact is to helps banks accelerate onboarding; rapidly reduce compliance challenges and financial risk; acquire validated customer data; and drive consistency and transparency. These factors help speed up time to revenue.

Want to revolutionise your customer onboarding strategy in 2023? Get in touch to discuss your needs.

Product Updates
Product Updates
Sales Intelligence
Sales Intelligence
SME Economy
SME Economy
Risk Management
Risk Management
KYC / KYB
KYC / KYB
Digital Transformation
Digital Transformation
Customer Lifecycle Intelligence
Customer Lifecycle Intelligence
Customer Experience
Customer Experience
Customer Due Diligence
Customer Due Diligence
Current Affairs
Current Affairs
Client Onboarding
Client Onboarding
Business Automation
Business Automation
Financial Services
Financial Services
B2B Corp
B2B Corp
FinTech
FinTech
Insurance
Insurance
Banking
Banking