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Sanctions Update: How to navigate the rapidly evolving sanctions landscape
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Justin Fitzpatrick
In February 2023, the British government marked the one-year anniversary of the invasion of Ukraine by issuing further sanctions against Russia.
Doubling down on efforts to cripple the Russian economy, and Putin’s ability to wage war on Ukraine, the Foreign Secretary announced a package of sanctions including export bans on every item Russia has used on the battlefield, import bans of iron and steel goods, 1,500 additional FCDO targets, and 92 individuals and entities (including 4 banks).
Indeed, the UK sanctions list now covers more than 1,551 of Russian’s most significant and high-value individuals and 180 corporate entities and subsidiaries, effectively shutting out huge sectors of the Russian Economy from international markets.
Complex, volatile, and rapidly evolving, the current global sanctions landscape, with its vast range of country-specific regulations, is a huge compliance challenge for financial institutions (FIs). In total, the latest sanctions list update covers 3,788 individuals and entities from 23 countries, plus specific sanctions lists covering ISIS and Al Qaeda, chemical weapons, counter terrorism, cyber, anti-corruption and human rights.
A complex geopolitical landscape
FIs are required to ensure that the individuals, entities, and subsidiaries they do business with are not subject to sanctions. However, achieving compliance and staying compliant is an incredibly complex process. Increasing regulatory scrutiny, as well as the inconsistent nature of global regimes, is putting intense pressure on FIs to raise the bar for sanctions compliance and awareness.
As part of customer due diligence, including know-your-customer (KYC) and know-your-business (KYB) checks, FIs need to be able to scrutinise their customer base to:
- Offer support to Ukrainian businesses or companies with Ukrainian links
- Improve awareness of companies with links to sanctioned countries, organisations, and individuals
- Identify Ultimate Beneficial Owners (UBOs) from sanctioned countries and organisations
- React quickly to regulatory change.
FullCircl has a number of tools to help
Take a look at our Russia-Ukraine guidance note covering:
- Company reports
- Company ownership and UBOs – including our UBO API endpoint
- Watchlists and watchlist filters.
In addition, we also provide:

Regulation spotlight: FCA kicks off 2023 by penalising banks for inadequate AML risk management systems
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Lucy Huntley
If you thought the FCA would back off following a raft of heavy fines imposed for breaches relating to anti-money laundering (AML) systems and controls in 2022 - think again.
Doubling down on efforts to reduce and prevent financial crime, the regulator has started 2023 the way it means to go on by issuing several multi-million pound enforcement actions in the first few weeks of the new year.
FCA principle 3 – Management & Control
The enforcements taken so far this year centre on failures under Principle 3 of its handbook – Management & Control. This requires that banks and financial service providers take reasonable care to organise and control their affairs responsibly and effectively, with adequate risk management systems.
It’s worth noting the FCA doesn’t require an incident of money laundering to have actually occurred in order to take enforcement action under Principle 3. The requirement is simply that management and control failures have the potential for money laundering risk.
Let’s take a look at four common failings, and examples of best practice responses from the financial service industry…
Best Practice AML Risk Management Systems
- Insufficient Onboarding intelligence
The FCA requires firms to apply appropriate Know Your Customer (KYC), customer due diligence (CDD) and enhanced due diligence (EDD) measures when establishing new commercial relationships. KYC is the backbone of a robust AML control framework. Shortcomings in KYC, CDD and EDD at onboarding stage negatively impact the robustness of risk management controls throughout the customer lifecycle.
Santander is shining example of a bank that has fully committed to plugging the highly publicised gaps in its AML controls at onboarding stage, to ensure they meet the FCAs high standards for compliance and risk management. Santander created a fully digital onboarding process that streamlines the customer experience, whilst ensuring all necessary KYC, CDD and EDD checks are performed by surfacing connected intelligence from billions of validated and verified third party data sources.
Not only does this mean Santander complies with Principle 3, but they also meet demanding CX expectations. Santander has successfully reduced time to onboard 75% of complex customers from the previous 14-21 days, to just five days.
- Inadequate continuous monitoring
Unfortunately, there is still a strong reliance on periodic reviews and manual approaches across the financial services industry, leaving banks and financial institutions at risk of failing to meet FCA expectations regarding ongoing monitoring – whether that be of customers or the supply chain.
Schroders Personal Wealth (SPW) offer a fantastic example of industry recognised continuous in-life monitoring approach.
If an FSI lacks complete real-time transparency and visibility over its entire supply chain ecosystem, then unidentified material changes can breach regulatory and legal compliance.
SPW harnesses a multitude of official and third-party sources to provide a real-time, accurate and contextualised view about any supply chain organisation, large or small. SPW monitors 366 3rd, 4th, and 5th party suppliers daily, 160 of which support its critical business process. Layered over this rich real-time business intelligence SPW harnesses a rules engine customised to the unique visibility needs of its supply chain. Using 28 bespoke rules it automatically spots specific risk triggers - including non-compliance with regulations, increased debtor days, directorship changes, UBOs, insolvencies, changes in credit score, Delphi score reductions, and potentially high-risk countries and/or industries – to always achieve a mission control view over its entire supply chain ecosystem.
- Lack of prompt action
A common failure is the inability to spot and act on red flags immediately. To ensure compliance with Principle 3, banks and FSIs need their compliance teams to be automatically notified of changes to clients’ credit scores, adverse media, CCJs, Gazette notices, adverse director history, PEPs and sanctions lists and more. This ensures they are not only protected from exposure to unnecessary AML risks, but that they can remediate risks quickly and efficiently.
Metro Bank has taken a revolutionary tech-driven approach to bringing compliance and KYC into the forefront of its business and commercial banking activities. Abandoning analogue processes in favour of a data-driven approach, Metro Bank knows more, knows sooner, and saves valuable time in the process - finding 14% more critical risk issues and reducing the average case time from 200 minutes to 8 minutes (a 94% improvement).
- Failure to align process to policies
To be fully compliant with FCA rules and money laundering regulations, a bank's or FSI’s processes also need to match their policies.
In response, many banks and FSI’s have integrated a rules-based decision engine to automate KYC and AML checks and achieve complete customised control of their compliance with Principle 3. One such institution is Metro Bank, who have implemented policies with a decision engine for faster, automated KYC, AML, and credit checks.
Metro Bank combines everything it knows about its customers, business, and market, and leverages an advanced decision engine that ingests millions of structured and unstructured data points to layer on top of that know-how. This approach quickly delivers the impactful insights and risk intelligence needed for next-generation prospecting, customer monitoring and engagement, advanced onboarding, and ongoing assessment of portfolio risks and opportunities.
By aggregating data from a multitude of different sources and mapping that intelligence to its risk appetite-based rules framework it can flag issues immediately and deliver an onboarding process that is 94% faster than previously achieved.
Don’t risk finding yourself in the glare of the FCA’s spotlight
The FCA has made it clear - there is simply no excuse for a failure to comply with money laundering rules and regulations. If you’re interested in learning how FullCircl can deliver complete confidence in your KYB and AML risk management systems, please get in touch.

Digitisation in Insurance: How to use data and technology to build a more customer-centric future
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Ashleigh Gwilliam
The pandemic certainly accelerated digital transformation in the insurance sector. For an industry that had long been perceived as lagging behind its financial service peers, insurance businesses demonstrated remarkable agility, flexibility, and resilience in overcoming a host of obstacles. But in 2023 the challenges continue to mount.
There’s a need to refocus once again in the face of tough economic and geo-political circumstances, and a persistent urgency remains to reinvigorate the customer experience in line with evolving post-pandemic expectations, especially in the traditionally underserved SME sector.
Vast changes are still needed. But the window to make them is shrinking, and the need to accelerate next-generation digitisation is greater than ever.
What does the future of insurance look like?
To answer that question, we asked the people helping to shape it.
For our latest whitepaper we spoke to experts from across the insurance industry to understand the key challenges insurers, brokers and MGA’s are facing. With insights from commentators from both the Lloyds and company markets, as well as the fintech/insurtech community, our report sets out:
- The current state of play
- The need for innovation and the appetite for change
- Why embracing new technology is vital
- What insurtech 2.0 really looks like
To find out how to use data and technology to build a more customer-centric insurance future, download your free copy now.

How to maintain a competitive advantage in the insurance industry (when you can’t compete on price)
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Ashleigh Gwilliam
It’s getting tougher for commercial lines brokers to compete on price alone.
Harsher economic conditions have created a hard market, with insurers setting higher premiums and less generous policy terms. This is due to increased risks in the business environment caused by Brexit, the pandemic and Russia’s war with Ukraine; plus double-digit inflation hiking the cost of replacing stolen or damaged items.
In this more complex market, brokers are finding it harder to win new clients and keep them. They are also having to justify premium hikes in a way that doesn’t damage hard-won and important relationships with their clients. All of this makes maintaining a competitive advantage in the insurance industry a challenge.
Cheapest doesn’t cut it
Before the pandemic and in other times where the market was much more buoyant, some brokers felt they could win and retain customers simply by looking for the cheapest quote for them; however, in the hard market currently being experienced by the industry, brokers need to do much more to remain competitive, compliant and attractive to new/existing clients.
Price will always be important, of course it will, but there are other, more innovative, ways to achieve a competitive advantage in the insurance industry. In-depth market-led customer service is becoming key. Brokers wanting to remain competitive in a market where premiums are increasingly expensive should focus more on advising clients about the best scope and terms of cover, with regular communication and data-led insights.
They should delight the customer at the onboarding stage and continue to offer them vital data and insights through the policy term. The days of engaging with the customer at the onboarding and renewal stages are well and truly over. This article will discuss broader means than simply premium costs that will keep clients engaged and help your insurance brokerage establish and maintain a competitive advantage in an increasingly hard market. So where do you start?
Tactics for a competitive advantage in the insurance industry
Boost your know-how
Holding chartered status with the Chartered Insurance Institute (CII) is a good sign that the broker prioritises technical knowledge and understanding.
Customers know that, while many excellent brokers do not hold Chartered status, not having Chartered status can sometimes skew the focus onto price, rather than all-round advice. Customers realise that focusing on price only could ultimately hurt them if the policy doesn’t cover their needs fully.
Competitive insurance brokers can have much better conversations with clients by building their know-how and understanding of:
- Key issues impacting the underwriter
- Their specialist industry
- Each client’s situation
- Technical terms, contracts, and risks
A Customer Lifecycle Intelligence (CLI) platform is critical as it provides good data and insights on companies, sectors, risks and much more. It can alert you to any changes and allow you to intervene if one of your clients is flagged as potentially being in trouble.
Get friendly with your underwriters
The commercial lines insurance brokers with a competitive advantage tend to have fostered good relations with underwriters to ensure they get fast and favourable quotes. This includes taking time to understand what’s happening in each underwriter’s world. Like any business, having a good relationship with your contact and developing a solid track record of excellent conduct will keep you front of mind. The hard market makes it even more important in the relationship building/maintenance between underwriter and broker.
Take the Financial Services and Markets Bill, currently moving through the House of Lords. This bill will attempt to improve the UK’s global competitiveness post-Brexit by repealing some EU financial services laws with the aim of making the legislation meet the specific needs of insurers and other financial institutions based in the UK.
This includes replacing the Solvency II regulations with a proposed Solvency UK regime that aims to increase flexibility for UK insurers and free their capital for investment in technology and infrastructure. In theory, it should allow insurers the opportunity to be more price and risk-friendly which will certainly offer competitive advantages.
Brokers will need to have an in-depth understanding of how UK-based insurers are responding to the Financial Services and Markets Bill, and who could quote them better prices and terms as a result.
Target underinsurance in your specialist sector
Underinsurance is a massive threat in the current market, and can leave companies significantly exposed. Challenges such as war in Ukraine, inflation and more extreme weather could mean companies unwittingly have much less cover than they need in policies from property and asset insurance to key person cover. One example of this is a policy that covers the company for a pre-agreed insured sum in the incidence of a fire but has not taken into account how double-digit inflation has increased the cost of materials.
Gaps are widening between the sum insured figure and real time replacement costs and it’s vital to keep on top of how this is impacting - or exposing - your clients.
Brokers wishing to maintain a competitive advantage in the insurance industry will avoid fear-mongering around these issues and instead discuss, collaboratively, the importance of protecting against those risks at the right level. They use real time data-driven insights to support that conversation and, where necessary, ask the client for more details to ensure they get the right cover for the next year.
A good broker will also keep an eye out in case companies become underinsured mid-term, advising them of this accordingly and having a solution ready and waiting.
Up-to-the-minute data insights could help with cross and upselling to your portfolio as well.
A CLI platform can help you stay competitive
In-depth data from a CLI platform could, for example, show how growing export turnover is the perfect time to discuss marine insurance. Falling cash reserves should spark a chat about trade credit insurance.
If data shows that client’s revenue and profit are growing fast, you can talk about increasing cover in their business interruption policies. A good knowledge of the client’s previous revenue and profit figures over several years can help guide that conversation, as it shows their growth trajectory.
All these data-led conversations can boost loyalty by ensuring your client makes well-informed decisions. A client facing unique worries in their particular sector will appreciate your looking out for them and keeping their needs at the forefront. Plus you’re more likely to keep the business at renewal if you’re giving data-based advice that is based on up-to-date information.
Rival brokers without that capability will not have anywhere near as much to work with when trying to demonstrate their value.
Grow your customer service
Competitive commercial insurance brokers build their reputation as trusted advisers with a continuously proactive approach throughout the policy term.
Don’t go silent for 12 months until it’s time for renewal. Keep in touch with clients to find out if there have been any relevant changes. Customer service is more than simply reacting when your client needs something. The level of customer service that you need to achieve to remain competitive in a hard market is proactive as well.
Using data and insights to inform them of events that might affect their policies, such as new regulations or legal amendments, will showcase your value and engender the kind of trust and relationships that will be beneficial, come renewal
Check in with your clients regularly, even if they only have time for a 15 minute call. This allows you to temperature check and gauge how your contacts are feeling while adding value to those conversations with tailored, real-time data and insights.
Track important company events and personnel changes
When policies lapse or are lost to other brokers, it can be due to a senior management change - for example, if the new finance director’s previous broker follows them to the new organisation.
Many brokers with a competitive advantage in the insurance industry make use of a CLI platform that alerts them if any senior managers leave their commercial customers. This allows them to call up, advise that they are aware of the change and request a meeting with the new senior manager to ensure the cover remains up to date.
A platform can offer a long list of customisable alerts, including for events that may trigger potential claims, from floods to health and safety investigations. This enables you to proactively reach out to clients and help them. It gives you genuine reasons for getting in touch and building credibility.
If possible, as well as a regular status check, have quarterly in-depth catch-up meetings with the client, and involve insurers where necessary. Build tripartite relationships, working together with the client and insurer to get the best terms. This improves trust and confidence with the client because they know whoever looks after their policy and any claims personally.
How FullCircl can help you maintain a competitive advantage
FullCircl‘s revolutionary CLI platform helps you sharpen your focus on the companies that fit your specialisms and sector.
It empowers your team with rich, contextualised information on every business in the UK and Ireland, and can boost your sales capacity tenfold. It provides everything you need for precision prospecting, with real-time data on filters from geography to turnover, headcount and fleet size.
FullCircl provides tailorable filters that alert you to key client events – such as management changes, expansions, or changes to risk profile. It also offers real-time information on claimable events, such as disasters in filtered regions, and legal changes.
This helps you give prospects and clients the right support and guidance when they need it, and in turn gives you a competitive advantage.
Drop us a line to find out more.

FullCircl and BIBA open the discussion on the biggest broker challenges of 2023
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Ashleigh Gwilliam
The BIBA manifesto for 2023 is “Managing Risk – Delivering Stability”. And that’s exactly what we did on 26th January 2023, when we brought together over 60 handpicked senior leaders and influencers to dive deep into two of the biggest challenges impacting brokers in 2023 - namely the hard market and underinsurance.
Now is the time to have the underinsurance discussion
Steve White, CEO of BIBA, led the discussion on underinsurance.
With inflation, the rising cost-of-living and cash flow difficulties, the war in Ukraine, energy prices, and high labour and materials costs, we’re currently in the eye of the perfect storm for significant underinsurance.
Aviva’s Risk Insights Report 2023 highlighted that two-thirds of UK business leaders (63%) are ‘worried’ about the impact of the cost-of-living crisis on their business, while 29% believe it will have a ‘serious’ impact on their business. It also pinpointed some startling figures about the impact, with a fifth of businesses (21%) having reduced or considered reducing their insurance cover in the last year. Half of UK business are now actually considered to be underinsured to some degree, and 40% of policies with buildings cover have at least one premises suspected to be underinsured.
These figures are backed up by CILA, whose recent research found that underinsurance is found in 40-50% of claims. Underinsurance in the commercial sector is also wide ranging, with Premium Credit Ltd reporting that 21% of businesses have stopped buying employer’s liability cover, 22% have cut back on professional indemnity, 21% on public liability, and 19% on business interruption insurance.
So, how can brokers rise to the challenge of tackling underinsurance?
The worst scenario for business owners is to get their first experience of underinsurance when they make a claim. The key to tackling underinsurance is to move from a reactive approach, to a proactive or ideally predictive one. Guests at the event were all in agreement that utilisation of data is the fastest and most accurate way to identify customers who are at risk of being underinsured.
Failure to tackle this issue will not only damage the viability of businesses, particularly SME’s, but also impact the future success of brokers themselves - let’s be honest, they aren’t having an easy time of it either.
Our event survey found that 24% of insurance leaders agree or strongly agree they are finding it harder to win new business, whilst 59% are finding it harder to retain existing clients.
The event certainly kickstarted an urgent discussion, one that is perhaps long overdue.
What about the hard market? Has it plateaued?
David Sparkes, Head of Compliance and Training at BIBA took over talk about the current hard market conditions facing brokers. He promised lots of facts and figures, and he didn’t disappoint.
According to Marsh’s Global Insurance Market Index, for the third quarter 2022 property insurance pricing increased 6% year on year, and casualty pricing increased 4%. Rates remained competitive for EL and PL. Financial and professional lines pricing have flattened out, and cyber pricing increased 66% year-on-year in Q3, down from 102% in Q2.
So, the evidence might suggest that the hard market is plateauing. But David urged that we should not be too hasty to jump to this conclusion.
The December 2022 Reinsurance renewal programme highlighted that the 5-year moving average for 2022 was the second largest on record, thanks to a rise in perils and macro trends including inflation, high interest rates, heightened investment risks, climate and ESG, shareholder pressure and underinsurance.
David’s assertion that we shouldn’t speak to soon when it comes to the continued impact of the hard market was reinforced by the insurance leaders attending the event. 34% agreed that the hard market is having the biggest impact on their future plans, whilst 36% also said it is the biggest challenge to their growth aspirations.
Despite the challenges brokers can be confident of a brighter outlook for 2023
Not because these issues are going to disappear, but because brokers are ready to tackle them head on.
82% of respondents to our survey agreed or strongly agreed they are putting in place steps to combat such challenges, along with others including regulation, Brexit, the talent shortage, and the ongoing fallout from the global pandemic.
The discussion doesn’t end here
At FullCircl we love to listen, and we love to chat. Join the discussion or find out how we can help you harness data to tackle the biggest challenges impacting your organisation this year.
Or why not join us at the BIBA Conference
FullCircl is proud to continue supporting the BIBA Annual Conference as an exhibitor.
We look forward to welcoming you to stand G10 where we can discuss the challenges you’re facing. Come and see us, meet our team, and tell us about your challenges so we can rise to them together.
Spoiler alert 🚨…
We will also be showcasing our new FullCircl X Acturis integration, a new connected solution for brokers, insurers, and MGAs that promises to deliver meaningful opportunities to drive growth through rich, contextualised, and connected company intelligence.
Follow us on LinkedIn for the latest updates on our plans for the event, including our exclusive drinks party.

2022: Our Year in Review
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Justin Fitzpatrick
FullCircl’s highlights and achievements
2022 is already a distant memory. The start of a new year is the perfect time to look back at what’s been accomplished, and what we can learn from the challenges faced, as well as looking forward to the opportunities ahead. 2022 was certainly a year of uncertainty, but as Benjamin Franklin once said, “out of adversity comes opportunity”.
2022 was year of great opportunity here at FullCircl, as we supported our customers in responding to their unique challenges and opportunities. But before I explore this further, I would like to take a minute to say thank you.
Thank you to all our customers for inspiring us, trusting us, innovating with us, being part of our journey, and letting us be a part of yours.
Here’s a look back at our highlights and achievements…
FullCircl’s highlights and achievements
On 1st March we announced the final stage in the merger of Artesian and DueDil. Launching FullCircl to the market was a milestone achievement in the evolution of our business. This new brand identity captures our highly differentiated Customer Lifecycle Intelligence (CLI) proposition, and our bold vision for the future.
More than just a name change, our new brand consolidates all the best things about both businesses into one unified solution that is a true ally for regulated businesses.
From the outset there was strong rationale for bringing our businesses together and it’s been so encouraging to see how positively the market has responded to our proposition.
FullCircl is the only provider to offer a single solution for better decisions across every stage of the customer lifecycle. In 2023 we will cement our position as the only CLI platform that goes full circle (now you get why we’re called FullCircl) - helping our customers meet demanding customer expectations, stay ahead of the competition, and navigate the complexities of changing regulation - and, in doing so, deliver a demonstrable return on investment and the guarantee that they will realise value early and often.
We helped our customers grow
We now represent 7 out of the top 10 UK banks, 80% of all CMA9 institutions, and are the trusted platform for over 600 brands and 15,000 users, helping them grow by doing Better Business, Faster.
How do we do it?
CLI helps companies:
- Win the right customers – through tailored news and data-led insights on companies and their officers
- Onboard faster and with confidence – KYC screening for customer suitability, verification checks via a rules-based decision engine, and automated onboarding journeys powered by our API
- Keep customer for life – proactive monitoring and in-life customer care based on configurable rules to spot risks and opportunities faster
We kept up an exhilarating pace of innovation
If incorporating the best of both platforms, building a differentiated CLI proposition, and rebranding our business wasn’t enough, through our relentless drive for continuous product innovation we also launched several new features including:
- Company Group Explorer – a visual way to discover company hierarchies so regulated business can improve onboarding and reduce risk
- HMRC Import and Export Data Extension – allows users to understand which of their customers are trading internationally
- Sustainability Gazette – regular summaries of the latest ESG initiative across every market in which customer operate
- Sanctions Assistance – a free service aimed at helping our customers navigate the increasingly complex yet highly critical political landscape
- Major improvements in data infrastructure for richer and more accurate information for our customers clients, including unified monitoring for more holistic decision making , perpetual monitoring and advanced KYC and due diligence, and the delivery of actionable event alerts
In a major milestone which brought two of our market leading solutions together, we integrated our API and decision engine to enable customers to programmatically screen their customers and prospects based on customised rules and policies. This allows them to reduce cost to serve by automating pre-screening, executing compliance checks at point of origin, and bringing new levels of speed and efficiency to onboarding activities.
We made lots of new friends
We’re big believers in the value of innovation partnerships - the advantages they deliver to our customers, the opportunity to collaborate to accelerate innovation, and their ability to create new markets.
In 2022 we announced new data and technology partnerships with:
- Umazi, the enterprise digital identity provider, to automate and accelerate SME corporate due diligence
- NayaOne marketplace and digital sandbox to make CLI even more accessible to a diverse range of financial institutions looking to accelerate their business transformation
- Codat, the universal API for small business data, to provide integrations to the accounting platforms used by the majority of UK SMEs.
- Wiserfunding, to provide the most accurate SME credit risk analysis
- nCino, to provide a comprehensive compliance and risk assessment platform
As we move into 2023, we plan to bring you even more exciting partnerships, each of which will play key role in our journey. Shared growth through working together is a win-win for you, for us, and for our partners.
Our team continued to grow
We increased our headcount by 20% in 2022, including bolstering our leadership team as well as our customer success, sales development, training, and enterprise account management teams.
Notable appointments include:
- Stuart Boardman as our new Director of Channels and Revenue partnerships
- Chris Hares as our new Chief Technology Officer
- Promotions for Ashleigh Gwilliam (Insurance Success Director), Lucy Huntley (Banking Success Director) and William Fields (Director of Sales).
So, what’s coming up in 2023?
Well, it’s certainly not job done - that’s for sure. Resting on our laurels is simply not in our nature.
This year will see us double down on delivering even more value from the Customer Lifecycle Intelligence within our platform and delivering an ever more powerful monitoring solution. That means more R&D, more product development, and more focus on developing propositions and a market leading customer success programme that helps our customers deliver products and services faster, safer and more cost effectively. Plus, more investment to ensure we always provide the best insights from the best possible data sources, along with new partnerships to support the critical functionality that has become so vital to transforming and strengthening our customers’ operating models.
It's going to be another great year. We can’t wait to get started, so stay tuned for updates.