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Crypto Asset

Briefing Note

TIME TO MICAR

Crypto-assets and DLT technology are consolidating in the financial industry. Avantage Reply brings the right skill-set to support banks and financial institutions in embracing with innovation and new business models meanwhile managing risks and uncertainty.

AML

Briefing Note

AML package

Fresh from the presses! A tidal wave is looming on the horizon of the AML landscape: the first European Regulation on AML/CFT, an independent and autonomous authority specific to AML... 2024 will be a landmark for financial crime regulation!The GRC Team is proud to present an in-depth look at the AML Package set to be adopted by the end of the year.

Briefing Note

Six Design Principles for Bank Risk and Control Operating Model Transformations in 2024

This briefing note functions as a starting point for banks’ senior management to identify key priorities and design decisions for risk and control target operating model (TOM) transformations in 2024. It has been developed by identifying the key supervisory priorities of the UK and EU regulators, analysing strategic risk management trends in the industry, and leveraging Avantage Reply’s insights from developing target operating models for a range of risk and control functions at some of the most significant financial institutions across Europe.

Case Study

Risk Support

Avantage Reply provided support to the Risk department of a custodian bank that operates at an international level. The goal was to help with the completion of the department’s daily tasks and any upcoming projects

Case Study

Risk Management Support

The client began a project to switch to a new core banking system and aimed to complete this transition quickly with minimal impact on their daily processes and duties.

Case Study

Internal Audit of the Recovery Plan

The client, an independent and privately-owned banking group which provides private banking services, wanted an external expert to support their internal audit team. In particular, the client wanted to review and provide assurance that their Group Recovery Plan is in line with the latest regulatory requirements and best market practices.

Case Study

Standardized Approach for Counterparty Credit Risk

The client, a major banking group offering a broad range of financial products and services such as bilateral loans, trade financing and derivative products to corporate and institutional clients, required assistance with calculating the capital requirements for counterparty credit risk under the new standardized approach.

Case Study

Compliance Support

Avantage Reply supported the Compliance department of an internationally operating Private Bank / Financial Services Company in moving its European headquarters between countries. This involved PMO support, regulatory analysis and assessment of the Bank’s Compliance functions across several locations in the Eurozone, the UK and other European countries.

White Paper

Climate and environmental risk integration within the prudential framework: Sustainable-FRTB

Climate change will continue for many decades to come, Banks should adequately incorporate climate-related and environmental risk within their governance and risk management frameworks in order to mitigate risks.

Briefing Note

Solvent Exit Planning for Non-Systemic Banks and Building Societies

The Consultation Paper outlines the Prudential Regulation Authority’s (”PRA”) proposals for non-systemic banks and building societies in the UK to prepare, as part of their business-as—usual activities, for an orderly ‘solvent exit’ and if needed, to be able to execute one.

Briefing Note

BCBS 239: A renewed ECB Priority

Since the release of the BCBS 239 Principles in 2014, the European Central Bank (ECB) has been urging European banks to comply with these Principles. These Principles cover three main topics: Overarching governance and structure, risk data aggregation capabilities, and risk reporting practices (often referred to by the ECB as 'RDAR').

Briefing Note

DORA - Overview of the Joint Consultation on the First Batch of DORA Policy Products

On 19th June 2023, The European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) launched a public consultation on the first batch of policy products under the DORA. This pack provides an overview of the four draft regulatory technical standards (RTS) and one set of draft implementing technical standards (ITS) released.

Case Study

Recovery Planning under ECB supervision

The client, an ECB-supervised bank, is required to maintain and update their Recovery Plan regularly. In this context, the client requested the assistance of Avantage Reply, to assist the bank in the production of its Group Recovery Plan.

Case Study

Enhancement of the Group’s ICAAP Framework

Avantage Reply undertook a project to assist an international banking group in enhancing its Internal Capital Adequacy Assessment Process (ICAAP) framework in alignment with best banking practices.

Case Study

ICAAP/ILAAP Reports Update and Enhancement

Avantage Reply assisted a client with their objective to produce two regulatory reports namely the Internal Capital Adequacy Assessment Process (‘ICAAP’) and the Internal Liquidity Adequacy Assessment Process (‘ILAAP’).

Case Study

Regulatory Reporting Support

In the context of transferring banking activities to another partner, the bank (the client) must comply with European banking authority (EBA) reporting requirements. The bank is required to produce regulatory reporting on a monthly and quarterly basis (i.e., COREP, FINREP etc.) Avantage Reply was engaged to provide support and expertise to generate regulatory reporting.

Case Study

ILAAP Internal Audit Support

Avantage Reply assisted the internal audit department of a leading private bank in the Eurozone, a less significant institution (LSI) that is part of an international group.

Briefing Note

SMCR Overview for 2023

The SM&CR was introduced in response to failures in senior management conduct and accountability evidenced in the Global Financial Crisis of 2008. The regulatory expectations under the regime are proportional to the degree of influence a stakeholder has on the firm’s decision-making. In particular, it is categorised under three key elements.

Briefing Note

Unique Product Identifier - UPI

The Unique Product Identifier (UPI) is necessary to improve transparency and reduce risk in the OTC derivatives market, but implementing it poses challenges for financial institutions, including data quality, system integration, cost, and industry coordination. High-quality data and system integration are crucial for effective implementation, and coordination is necessary for consistent global adoption.

Case Study

Support to Risk Management: Risk monitoring tool migration

The client is a large multinational asset management company. The customer needed assistance on the migration of its risk monitoring tool (from RiskMetrics to Aladdin Risk). Avantage Reply supported the client on the risk monitoring tool migration as Project Manager, leveraging on industry knowledge and internal know-how.

Briefing Note

Last amendment on SFTR

The European Securities and Markets Authority (ESMA) released an update to Validation Rules and XML Schemas for the Securities Financing Transaction Regulation (SFTR) and Reply’s team will support you in defining the main impacts.

Case Study

Liquidity & Interest Rate Risk Assessment on Complex Financing Structures

Avantage Reply assisted a well-known universal bank in the Eurozone to analyze, assess and document the potential liquidity and interest rate risks related to complex financing structures. The tailor-made financing solutions are important for more sophisticated clients, mostly corporations with precise financial needs, and aim at financing them via term loans, leasing, liquidity raising, securitization or short-term investments.

Case Study

National Central Bank Reporting Support

Avantage Reply assisted the finance department of a well-known bank in updating its process to produce monthly and quarterly statistical reporting for the Nation’s Central Bank, following the publication of the updated guidelines. This guideline modifies the statistical reporting requirements for credit institutions

Case Study

Recovery Plan Update

The client, a subsidiary of a leading bank, is required to maintain and update their Recovery Plan on the regular basis. Given internal resource limitations along with new requirements, the client required an assistance in the review and update of the plan. Avantage Reply provided a recovery plan expert who 1) updated the plan according to the latest regulatory requirements and 2) integrated the recommendations received from the internal audit function as well as the national regulator.

Case Study

Support with Credit Risk Regulatory Inspection

The client, a European-based leading bank in online financial services that offers state-of-the-art solutions to meet investment needs, required support from Avantage Reply on the preparation of a regulatory inspection for Credit risk and IT-related topics.

Case Study

Finance Function Support

Avantage Reply supported the Finance department of an internationally operating custodian bank in their daily and monthly production of internal and regulatory reports, as well as other routine activities. The client was handling a large project, the complexity of which had to be managed, while simultaneously completing all regularly occurring tasks to the highest possible standard without any disruption.

Case Study

Supporting daily ALM activity and reporting

Avantage Reply assisted a Finance department of a well-known private bank in daily activity and reporting production of the Assets and Liabilities Management team. The key tasks were assist the team in the improvement and preparation of the Internal Liquidity Adequacy Assessment Process (ILAAP), advise on the regulatory requirements and contribute to the implementation of local.

Case Study

Testing of liquidity regulatory reporting in light of the new BO system

Avantage Reply assisted a Finance department of a well-known private bank in the connectivity test phase within back office tool migration. The project covered a wide range of activities such as conducting multiple User Acceptance Tests (UAT) with on-shore teams, verify the impact of the change on regulatory reporting.

Case Study

Finance reporting support

Avantage Reply assisted a Finance department of a well-known private bank in daily and monthly reporting production related to liquidity. The key tasks were: produce and certify various regulatory reports, such as LCR, AMT, NSFR incl. contributions to group consolidated reports; produce and certify integral liquidity reports based on inputs from various business line.

Case Study

AnaCredit – Data remediation Activity

Avantage Reply assisted a Finance department of a well-known private bank in daily and monthly reporting production related to liquidity. The key tasks were: Produce and certify various regulatory reports, such as LCR, AMT, NSFR incl. contributions to group consolidated reports; produce and certify integral liquidity reports based on inputs from various business lines...

Case Study

Single Supervisory Mechanism (SSM) Transition

The regulatory classification of banking institutions, concerning their competent authority, is an important aspect that determines a lot about their regulatory obligations. Based on several criteria, a bank may be deemed significant.

Briefing Note

BASEL 3.1: BRACE FOR IMPACT

The Bank of England has published its position on Basel 3.1 reforms, introducing a series of fundamental changes to the current prudential regulation regime in the UK. CP16/22 - Implementation of the Basel 3.1 standards has largely been adopted from BCBS standards and its core principle are aligned to global practices. However, there remain some key points of difference/divergence, specific to the practices in the UK market.

White Paper

EBA’S NEW REQUIREMENTS ON CSRBB MANAGEMENT

On 20 October 2022, the European Banking Authority (EBA)published new regulatory requirements on Interest Rate Risk and Credit Spread Risk in the Banking Book (IRRBB / CSRBB) aiming to finalise the implementation of Basel III requirements (BCBS368, Guidelines on IRRBB) in the European Union.

Case Study

Enhancement of Internal Rating Based Framework

The client, a major universal bank featuring a significant wealth management activity, was in the process of enhancing its IRB framework (Internal Ratings Based) following Basel IV requirements and feedback from the European Central Bank (ECB). This program has been launched to repair internal models used to calculate own funds requirements for credit risk under the Internal Ratings Based (IRB) approach.

Case Study

Remediation of the outsourcing control framework

In 2021, an internal systemic Bank launched a holistic risk assessment of its Depositary Bank (DB) business. As part of this review, Avantage Reply performed a review of DB exposure to risks related to outsourcing arrangements including the effectiveness of controls to mitigate associated risks.

Case Study

ILAAP Support

Following the Supervisory Review and Evaluation Process (SREP), the bank received a letter from the Banque Centrale du Luxembourg (BCL) highlighting a number of findings and recommendations concerning its liquidity risk management framework. The bank was asked to address these recommendations as part of its submission of the 2021 Internal Liquidity Adequacy Assessment Process (ILAAP).

Case Study

Risk and treasury processes automation

Following recommendations from Banque Centrale du Luxembourg (BCL) as well as the findings raised by its internal auditor, the bank wished to automate several operational and regulatory processes conducted by the Risk and Treasury departments.

Case Study

Pillar 3 Support

In the context of Pillar 3 on public disclosure requirements and with the implementation of the regulation known as CRR 2, the bank is required to produce and publish every year a Pillar 3 report (annual and semi-annual versions). Avantage Reply was engaged to provide support and expertise in the Pillar 3 and CRR 2 regulatory requirements implementation.

Case Study

Counterparty Credit Risk (Pillar 1 and 2)

The client, a major banking group specialised in the provision of online banking and trading services, was in the process of launching new derivative products for its retail clients and required assistance for the counterparty credit risk calculations and regulatory reporting of these products.

Case Study

Standardised Approach for Counterparty Credit Risk

The client, a major banking group specialised in the provision of online banking and trading services, was in the process of launching new derivative products for its retail clients and required assistance with calculating the capital requirements for counterparty credit risk under the new standardised approach. This project was a continuation of similar work which Avantage Reply performed prior for this client, regarding the mark-to-market approach.

Case Study

Development and implementation of the IRB-models

Avantage Reply supported a large bank in Luxembourg with a complete transformation of the internal credit risk model portfolio. In doing so, our team was involved in several steps of the model lifecycle: model development, model backtesting, model validation by the second line of defense, model review by the ECB and implementation of the model in the bank’s IT system.

Case Study

CRR2 Support

The client, an international central securities depository, required assistance in the transition to the new regulatory reporting requirements (i.e. Capital Requirements Regulation 2 / CRR2) coming into force in June 2021. In particular, the reporting function needed support on the following topics.

Case Study

Implementing capabilities of Data Governance

Avantage Reply assisted a local universal bank with the effective implementation of data governance capabilities. As part of a broader initiative to ensure the bank’s compliance with BCBS 239 principles, our client needed to document the key source data related to credit risk and ALM calculation tools. Additionally, there was a need to define, implement and run processes allowing remediation of data quality-related issues.

Case Study

Review and remediation of the entire client base regarding AML/KYC requirements and review of the AML/KYC processes.

Avantage Reply was tasked by a leading Wealth and Fund Management Bank to review and remediate the existing customer base KYC information, specifically for AML/CTF requirements. This task was required on the one hand due to changing regulatory requirements, on the other hand, because of the effect caused by Brexit on the customer’s UK branch.

Case Study

FRAUD RISK: AN EXAMPLE OF OPERATIONAL RISK ASSESSMENT

The client, a crypto-currency exchange, has requested Avantage Reply to assist with an ongoing project around fraud risk. As the regulation around virtual asset service providers is not yet mature, the measurement of new and non-traditional operational risks is not an easy exercise. In fact, several players in the industry have recently found themselves being vehicles for the continuation of various financial crimes, including fraud. In the client landscape, scammers and individuals with malicious intentions have exploited the weaknesses of decentralized finance (DeFi) and have misappropriated even millions of dollars from their victims through first party or third party external fraud.

Case Study

MIGRATION AND TESTING OF CREDIT RISK MODELS

Avantage Reply assisted a European Institution in implementing its own version of Credit Risk models and migrating from Moody’s RAY to a Java-based solution implementation. The institution needed Avantage Reply support to ensure smooth communication between the business and the developers and to ensure the correct migration and implementation of the new models. All the process required completed documentation.

Case Study

Embedment of ICAAP & ILAAP exercise

Avantage Reply has assisted a Private Banking group in the Eurozone in their embedment of Internal Capital Adequacy Assessment Process (ICAAP) & Liquidity Adequacy Assessment Process (ILAAP) exercise, s.c. ICLAAP. Following the recommendation of the European Central Bank (ECB), bank’s current practice of ICLAAP had to be reviewed and challenged. The results of the review have been presented to the Management Body. In particular, identified gaps and attention points with respective actions to improve the way ICAAP and ILAAP are conducted. The analysis has been enriched with market best practices observed among various financial institutions in the Eurozone.

Case Study

Functional Analyst

For a Top Tier Bank within its Data Quality Management (DQM) Department responsible for ensuring delivery of top quality reports to national and international regulators, the functional analyst joined the Agile team in charge of the liquidity-reporting tool: Moody's analytics liquidity solution.

Case Study

CAP support on Internal control framework and Third-Party Risk Management

The client is an insurance company where a team of insurance industry veterans who understand the challenges of MGAs and PA. Their goal is the implement and develop their business plan/action (already developed in Malta and in other countries) in the heart of Europe and other countries. We did support them in their policies, in their Third-Party Risk management (“TPRM”), in the completion of their risk register, in the support and control on the Risk Appetite Statement, in the completion of the Key Risk Indicators & metrics documents and in the support & control of the Own Risk and Solvency Assessment (“ORSA”) report.

Case Study

Senior compliance officer support - Special AML-CFT task force for client files review in an important Belgian retail bank.

Our client, one of the most important Belgian retail bank, has requested the help of Avantage Reply for the constitution of a special task force in the field of AML-CFT (anti-money laundering and countering the financing of terrorism (AML-CFT).

Case Study

IT Department Management Reporting Re-engineering

Our client is the IT department of a European retail bank and insurance company. They require future-proof financial reporting available to managerial levels of their organisation. To achieve these ambitions, we defined a new reporting framework together with our client, and implemented the necessary tools and processes on that foundation. It has led to a considerable reduced workload in the preparation of reports, freeing up time for value-added activities, increased flexibility in reporting as to gain more insights, and further autonomy for end-users.

Case Study

Senior compliance officer – Support the second line of defense of an important retail bank in transaction monitoring

Our client, an important Belgian retail bank, has requested the help of Avantage Reply for the support of its second line of defense team in the field of AML-CFT (anti-money laundering and countering the financing of terrorism).

Case Study

Internal control framework support

The project was performed for an insurance company acting in the non-life insurance market. As the company grew fast, they required support within the risk and compliance departments, to establish the risk and control register, to elaborate policies and procedures and to work on the due diligence process.

Case Study

CAP Risk Regulatory – Support for CRO

The client required support for different projects including those related to the National and the European regulators’ supervision. In particular, support was provided for researches about the Climate related Risks which is a recent topic covered by regulators. To achieve this objective, a daily ongoing support was performed and an in-depth researches on the Climate related Risk with a Regulatory Monitoring was provided.

Briefing Note

NEW SUPERVISORY REGIME FOR NON-SYSTEMIC BANKS

Following Brexit, the UK Government has sought out ways to improve, clarify, and simplify the regulatory regime for UK financial institutions. On April 29, 2021, the PRA published a Discussion Paper, “A Strong and Simple Prudential Framework for Non-Systemic Banks and Building Societies”, outlining its proposed changes to the prudential framework regime for non-systemic banks and building societies to ensure the resilience, stability, and soundness of smaller firms.

Briefing Note

SUPERVISORY EXPECTATIONS FOR NEWLY AUTHORISED BANKS

Following Brexit, the UK Government has sought out ways to improve, clarify, and simplify the regulatory regime for UK financial institutions. On April 15, 2021, the PRA published a Supervisory Statement, “Non-systemic UK banks: The Prudential Regulation Authority’s approach to new and growing banks”, outlining its supervisory expectations for newly authorised non-systemic banks in the UK.

Case Study

ICAAP and ILAAP report

The client, a banking institution specialised in financing companies, requested Avantage Reply’s assistance to prepare and provide recommendations for the ICAAP and ILAAP reports, and then based on the recommendations, align the reports with the regulatory requirements.

Case Study

Implementation of the supervisory stress test

Avantage Reply supported a large European bank with the submission of the 2020 ECB Stress Test exercise. The bank was looking for the assistance in implementing the new stress test methodology, completing all stress test templates, developing the explanatory notes and performing all necessary corrections during the ECB submission period. Avantage Reply supported the client through the 2020 ECB Stress Test as well as the 2021 post-COVID relaunch of the ECB Stress Test exercise. In addition, Avantage Reply carried out all project management activities during this project.

White Paper

EXPLORING THE IMPLEMENTATION OF THE EU TAXONOMY FOR FINANCIAL INSTITUTIONS

The birth of a general and structured regulation framing environmental performance of financial institutions creates a series of governance and practical questions within the industry. Its relative nascent stage requires an implementation far from traditional financial and risk reporting. Banks and Insurances, among others, need to anticipate the role of all their business lines, their data and insurers their top governance management in this implementation.

White Paper

Integrating Climate Risk into Credit Risk Modelling

This opinion paper note intends to describe the emerging practices in terms of integrating climate risk into credit risk modelling.

Briefing Note

Regulatory Reporting - Practical roadmap to implementing regulatory changes

The European Banking Authority (EBA) is responsible for setting harmonised prudential rules for financial institutions throughout the EU. To achieve this objective, the EBA has developed Binding Technical Standards and guidelines commonly known as Implementing Technical Standards (ITS) for regulatory reporting – standards that must be respected by all European financial institutions.

Climate change

White Paper

Climate risk stress tests – Challenges & Capabilities

The purpose of this paper is to share preliminary thoughts regarding climate risk stress tests including already planned ECB SSM climate risk stress testing exercise but also our service offer for French customers in terms of climate risk stress testing. It describes our main skills and capabilities including our analysis and acceleration tools before sharing the types of interventions that we cover and our credentials.

Stress Tests

White Paper

Stress Tests

The purpose of this paper is to share our service offer for French customers in terms of stress testing. It describes our main skills and capabilities including our analysis and acceleration tools before sharing the types of interventions that we cover and our credentials.

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