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18.01.2024

Blog

The Market in Crypto-Assets Regulation: a Deep Dive

The first comprehensive European regulation pertaining to the crypto-market was approved in May 2023 and is known as the Market in Crypto-assets Regulation (MiCaR). With the Fifth AML Directive, the Union had already regulated crypto-assets in the AML space, albeit under a different name: virtual currency.

07.12.2023

Blog

Risk and Compliance in the Digital Age - Assessing the Impact of the European AI Act

Many believe that artificial intelligence (AI) will be the "next big thing" in the digital era. Customers and businesses are increasingly using this technology to complete tasks that were previously limited to human operators and to solve problems.

08.11.2023

Blog

The clock is ticking on the Basel IV implementation – Are you ready?

On 27 October 2021, the European Commission (EC) published its legislative package, implementing the finalisation of the Basel III reforms, widely recognised as Basel IV. The Capital Requirements Regulation 3 (CRR III) and the Capital Requirements Directive 6 (CRD VI) were put in place to signify a new era of banking and financial compliance.

08.11.2023

Blog

DORA: The clock is ticking!

The Digital Operational Resilience Act (DORA), entered into force on the 16th of January 2023 and will be applicable from the 17th of January 2025. Its main purpose is to enhance and strengthen the cybersecurity practices of entities across the EU financial sector and to harmonise key requirements and reporting obligations.

07.08.2023

Blog

RAISING THE BAR: HM TREASURY’S CONSULTATION TO REFORM THE UK'S AML/CTF SUPERVISORY REGIME

On 30 June 2023, HM Treasury published a consultation on reform of the anti-money laundering and counter-terrorism financing (AML/CTF) supervisory. The consultation proposes four possible models and seeks respondents’ feedback on the potential benefits and drawbacks of each reform. Feedback and responses to the consultation must be submitted by 30 September 2023.

02.08.2023

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European Court of Auditors' Findings on the ECB'S Supervision of Banks' Credit Risk: A balanced view

On May 12, the European Court of Auditors (“ECA”) published a special report on European Union (“EU”) supervision of banks’ credit risk. It concluded that the European Central Bank (“ECB”) has stepped up its efforts but more is needed to increase assurance that credit risk, in particular non-performing loans (“NPLs”), is properly managed and covered.

02.08.2023

Blog

Trading wind-down: expectations and considerations

In a move to improve the resilience of the UK financial sector, the Prudential Regulation Authority (PRA) issued Supervisory Statement (SS) 1/22 in May 2022. This statement delineates the expectations for certain firms involved in trading activities that could pose significant adverse effects on the stability of UK’s financial sector.

27.06.2023

Blog

IMPLEMENTING THE CONSUMER DUTY FOR ASSET MANAGEMENT FIRMS

The Duty sets the standard of care that firms should provide to customers in retail financial markets. The FCA has introduced a new principle, Principle 12, known as the Consumer Principle. This principle requires firms to act in a way that delivers good outcomes for retail customers.

19.06.2023

Blog

The Future of Trading Books: Incorporating Climate Risk in Prudential Frameworks

On October 2022, the International Swaps and Derivatives Association (ISDA) released a report titled "Climate Risk Scenario Analysis for the Trading Book", which provides guidance for banks and financial institutions on how to assess climate risk in their trading books.

08.02.2023

Blog

CONSUMER DUTY: THE COUNTDOWN BEGINS

On 25 January 2023, the FCA published the findings from its review of firms’ plans to embed the Consumer Duty (the “Duty”) within their businesses. These implementation plans should have been agreed by firms’ Boards by the end of October 2022.

05.12.2022

Blog

2022 Annual Cyclical Scenario (ACS): What is new?

On 26 September 2022, the Bank of England (BoE) published details of the return to its 2022 Annual Cyclical Scenario (ACS). The ACS was not performed over the past two years during Covid-19 and postponed in March 2022 due to Russia’s invasion of Ukraine.

12.11.2021

Blog

Transforming Data Collection – The joint transformation programme

On Wednesday the 13th October 2021, the Bank of England (BoE) and the Financial Conduct (FCA) have announced the launch of the joint transformation programme on Transforming Data Collection, officially kicked off at the beginning of July 2021: this initiative follows the letter published on 23 February 2021 from the two authorities.

23.04.2021

Blog

From Operational Resilience
to Operational Excellence

At Reply, we support, guide and advise our clients in their Operational Resilience to Operational Excellence journey through our deep industry experience, leading strategic partnerships and proven framework.

15.10.2020

Blog

Negative Interest Rates - Are Banks Ready?

On 12th October, the BoE asked banks about their operational readiness and the challenges associated with the potential implementation of negative rates, particularly in terms of technological capabilities. Here, we contextualise this recent announcement against the BoE direction of travel over the summer and identify key areas of impact for banks.

12.10.2020

Blog

The Data Religion: Dataism in Financial Services

In my latest blog I reflect on Yuval Noah Harari's celebrated book, Homo Deus, delving into Harari’s fresh angle on the role of data in our day-to-day life. As I was contemplating Harari's spellbinding book it occurred to me that Dataism is, to a large extent, already the religion of the financial services industry.

01.10.2020 / Cloud Computing

Blog

Around the Cloud in Eighty Days – The Sixth Leg of the Journey: Cloud Regulation

This is Part 6 of our ten-legged journey to explore how the Cloud can enable productivity, innovation, and scalability in financial services.

21.09.2020 / Cloud Computing

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Around the Cloud in Eighty Days – The Fifth Leg of the Journey: Cloud Security

This is Part 5 of our ten-legged journey to explore how the Cloud can enable productivity, innovation, and scalability in financial services.

12.08.2020

Blog

Refining MREL – preparing to fail The

The EBA has published a consultation paper, seeking industry feedback on proposed changes to MREL requirements. Their intent is to better approximate the capital requirements & capital buffers inputs into the MREL calculation for firms whose banking groups are different from their resolution groups.

27.07.2020 / New banking applications

Blog

The Long Road to the Level Playing Field

The Bank of England has published two key documents in relation to the banking landscape in the UK for non-systemic banks. These proposals are a step in the right direction, but do they go far enough?

03.07.2020 / Cloud Computing

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Around the Cloud in Eighty Days: The Fourth Leg of the Journey: Operating Model and Governance

This is Part 4 of our ten-legged journey to explore how the Cloud can enable productivity, innovation, and scalability in financial services.

29.06.2020 / Cloud Computing

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Around the Cloud in Eighty Days: The Third Leg of the Journey: Architecture

This is Part 3 of our ten-legged journey to explore how the Cloud can enable productivity, innovation, and scalability in financial services.

11.06.2020 / Cloud computing

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Around the Cloud in Eighty Days: The Second Leg of the Journey: Infrastructure

This is part two of our ten-legged journey to explore how the Cloud can enable productivity, innovation, and scalability in financial services.

05.06.2020 / Cloud Computing

Blog

Around the Cloud in Eighty Days: The First Leg of the Journey

Jules Verne authored the novel Around the World in Eighty Days, Le tour du monde en quatre-vingts jours in its native French, which was published serially in 1872. It would presumptuous of me to rescript the story of the unflappable Phileas Fogg’s trip around the world, but allow me to take you on a ten-legged journey to explore how the Cloud can enable productivity, innovation, and scalability in financial services.

28.05.2020 / Fintech Magazine

Blog

Technology Enablement across the Wealth Management Value Chain: The Mass Affluent Opportunity

Market conditions are forcing financial institutions to find new models for growth. One of the largest identified gaps for growth is the underserved and overlooked mass affluent segment.

FEATURED IN FINTECH MAGAZINE

14.05.2020 / ESG Rating

Blog

Blind Reliance on ESG Data and Rankings — The Seeds of the next Mis-selling Crisis?

In early 2019, a survey of financial advisers had already revealed serious misgivings over the possible mis-selling of products marketed to investors as ‘ESG friendly’. 97 of every 100 financial advisors in the United Kingdom (UK) had declared themselves as either “very” or “fairly” concerned about the potential for allegations of mis-selling ESG investments, according to market research firm Cicero.

07.05.2020

Blog

The Cloud and the future of finance

A couple of weeks ago I had the privilege of co-authoring a short article on the adoption of the Cloud in Financial Services with Professor Nelson Phillips of the Imperial College Business School. We conducted several interviews with senior leaders in financial services about their experiences of moving to the Cloud. It turned out to be such a captivating journey that Nelson and I are planning to continue along this path and turn it into a much more comprehensive piece of research.

16.04.2020 / Coronavirus

Blog

Never waste a good crisis: the strategic challenges of rapid cloud adoption in financial services

One dramatic impact of the coronavirus (COVID-19) pandemic has been the rapid acceleration in the digital transformation of organisations as much of the workforce has been suddenly forced to “WFH”. The ability of organisations to close physical offices and continue operating rests largely on various kinds of cloud services providing distributed, on-demand availability of data storage and computing.

30.03.2020 / Remote Working

Blog

How to maintain business productivity with hundreds of employees working from home

With Covid-19 wreaking havoc on business and the economy, the only ideal solution is to respect Government guidelines while continuing business as usual — from home. The problem is, how can an organisation, in particular a financial institution, give hundreds or thousands of employees secure access to the documents and applications required to work from home without disruption to service?

20.03.2020

Blog

IT & DevOps in Financial Services (The Phoenix Project)

If, like me, you have to interact with IT —and technology is vital for you or your clients — this excellent novel will enlighten your day-to-day work. The Phoenix Project was first published in 2013 and, in the fast-moving world of technology, one could view this book as ‘outdated.’ But no. The way it articulates the value of DevOps for organisations remains insightful. It remains useful. And it remains worth your attention. Of particular value is the presentation of the Three Ways — the principles from which all observed DevOps behaviours are derived.

16.03.2020

Blog

It's all anyone is talking about...

It’s all anyone is talking about and, whilst I really wanted to write about something lighter, I was dragged back to the Reply Risk & Regulatory Academy, which has had the honour to run courses in Cambridge for many years. This led me to an incredible report published by the University there...

02.03.2020

Blog

Victor Hugo & the Green Swan: An Introduction to the threat of Climate Change on Financial Stability

There is something peculiar in the book released last January by the Bank for International Settlement and Banque de France, The Green Swan. The book builds on the concept of ‘black swans’ first introduced by Nassim Nicholas Taleb in 2007, but this time the swan is green. Green swans (or climate black swans), the authors argue, are extreme financially disruptive events resulting from climate-related risks.

21.02.2020

Blog

The Laundromat Movie: Meryl Streep discusses Anti Money Laundering & Counter-Terrorism Financing

Few realise just how corrosive the effects of Money laundering and the financing of terrorism are on society. That’s why, when we have the opportunity to assist our clients with their Anti Money Laundering (AML) and Counter-Terrorism Financing (CTF) initiatives, I find it exciting and rewarding.

14.02.2020

Blog

How to Teach Quantum Physics to Your Dog: Applicability to Financial Services

I had just finished reading Chad Orzel’s bestselling book ‘How to teach quantum physics to your dog’ last week when my colleagues presented what is perhaps one of the first concrete applications of ‘quantum-inspired’ computing in European banking. Before I turn to that, allow me to share a few words on Orzel’s book and how it got me to think about quantum computing in financial services…

07.02.2020

Blog

ECB SREP 2019 - Key Challenges for Eurozone Banks

On 28 January 2020, the European Central Bank (“ECB”) held a press conference in Frankfurt on the Supervisory Review and Evaluation Process 2019 (“SREP 2019”). It highlighted a number of interesting developments in the Eurozone. Allow me to share with you my key take-aways regarding the first three based on his remarks and the Question and Answer session that ensued.

05.02.2020

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The difficult child of regulatory reporting

In this period of annual closing and maximum effort for all reporting teams, you will probably agree that there is one that is particularly daunting. I am of course talking about the Pillar 3 disclosures.

31.01.2020

Blog

From the ski slopes of Davos: Do financial institutions have a responsibility to enforce climate and sustainability standards?

One of the main themes of Davos 2020 has been ‘climate and sustainability’. The World Economic Forum was most fascinating to me when it came to the clear divergence in thinking between financial institutions that want to cut polluters off from the financial system — and those that believe it is not the financial institution’s job to police the climate.

24.01.2020

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Regulatory Reporting: The Mote in The Banker’s Eye

Board members, Executives, Chief Financial Officers and Heads of Regulatory Reporting have plenty to fear as regulatory reporting by financial institutions comes under increasing scrutiny from regulatory bodies.

17.01.2020

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Click here to kill everybody - especially if you work in financial services

The number one mistake people make regarding technology is they don’t realise that, with smart devices, the internet can kill people. This is a real and relevant risk to the financial services industry, too.

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Operational Resilience: An evolving and challenging landscape

What is the operational resilience landscape, and how does it link with the 2022 regulatory priorities? In this blog, you will find the key points from David Bailey and Duncan Mackinnon's latest speeches and highlights from the new policy Statement PS2/22 | CP21/21 - Operational Resilience and Operational Continuity in Resolution.

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Bufferati: a simpler alternative?

"Bufferati speech" - what could it mean for the financial sector & could it achieve the aim of simplifying the current capital buffers regime?