Financial institutions – compliance & risk management
July 2018 | ROUNDTABLE | BANKING & FINANCE
Financier Worldwide Magazine
July 2018 Issue
In addition to being attractive targets for hackers, criminals and state actors, financial institutions (FIs) are subject to multiple requirements under data protection and financial services legislation, as well as criminal law in each jurisdiction in which they operate. Consequently, compliance and risk management are at the forefront, with FIs facing numerous issues related to the implementation and function of new technological financial products and services. Going forward, risk mitigation for FIs will depend on their ability to evolve with challenges and identify key areas where resources can be invested.
FW: What, in your opinion, are the most significant risk management and compliance issues currently facing financial institutions (FIs)?
Stott: Cyber security is one of many key areas of risk for FIs, which are custodians of vast amounts of data across multiple jurisdictions. FIs are attractive targets for hackers, criminals and state actors, and are subject to multiple requirements under data protection and financial services legislation and the criminal law in each jurisdiction in which they operate. This is an area of focus, both for the Financial Conduct Authority (FCA) and the Information Commissioner’s Office (ICO), which are working increasingly closely together. It will not be a surprise if the recent entry into force of the General Data Protection Regulation (GDPR) is quickly followed by action by either or both the FCA and the ICO in respect of cyber-related breaches.
Brechan: One issue that FIs find increasingly difficult to address is transactions with uncertain sources and inherent risk that regulators may afterwards, and with the benefit of hindsight, fine FIs substantial amounts for authorising. Typically, we have seen that operators of bitcoin mining are finding it difficult to establish bank accounts. Another key feature is the use of FinTech products, as FIs need to adopt new technology to respond to customer requirements and the growing appetite for streamlined, digital processes. Such technology will inherently pose risk and compliance issues.
Lipworth: There are many issues facings FIs. In the UK, apart from Brexit, there is cyber risk, the GDPR, the second Markets in Financial Instruments Directive (MiFID II), the Payments Services Directive (PSD2) and the extension of the Senior Managers and Certification Regime (SMCR). In the US, the Customer Due Diligence (CDD) rule is now in force and applying it is not going to be straightforward for many FIs.
Wong: There are three main issues that FIs face: regulatory compliance, adapting risk management models to a shifting environment, and minimising risk cost-effectively. However, in Vietnam, there are additional concerns, namely ineffective and unsustainable supervision and risk management which leads to a high rate of liquidity risk and credit risk, internal management risks, such as human and FinTech challenges, and a comprehensive risk management framework using Basel II.
Diehl: The most significant risk management and compliance issues currently faced by FIs are those related to the implementation and function of new technological financial products and services, including, among others, credit scoring, digital onboarding, fraud prevention and cyber security.
FW: What do you consider to be the most notable legal and regulatory developments presently impacting the way FIs approach risk, compliance and reporting processes?
Brechan: The obligation to register and continually update information as to ultimate beneficial owners under the fourth Anti-Money Laundering Directive (AMLD) is the most notable development. The largest Scandinavian banks have entered into a joint venture that would collect and monitor customer information and make it available to FIs on a subscription basis. The use of FinTech and the need for FIs to focus on banking means that there is an increasing desire for FIs to outsource back office operations and use modern means of social interaction, such as ‘Facebook Workplace’. Regulators are finding it increasingly difficult to assess whether a contract is business related, subject to notification, pertains to outsourcing, subject to filing and staying period, or is crucial to the business, prohibited.
Lipworth: Without singling out one development, the challenge is really the fact that the regulatory environment is changing more rapidly than ever before. It is constantly evolving and compliance teams have to be increasingly agile in spotting developments early and gearing up to promote change across their organisations.
Wong: Basel II has significantly impacted Vietnamese FIs. The pros are that FIs have been provided with a set of international model standards, as well as a greater ability to recognise and manage financial risks. It also means protecting capital from a financial crisis or market volatilty, and contributing to the stability of Vietnam’s macroeconomy. However, there are some drawbacks. For example, the roadmap to implementation is so complicated that banks and FIs need thorough instruction from the State Bank of Vietnam (SBV). Furthermore, the contradictory nature of raising capital – not raising enough capital decreases the capital adequacy ratio (CAR) that falls below the minimum requirements of the SBV and Basel II – impacts a bank’s growth.
Diehl: In Argentina, the most notable regulatory development in connection with the way FIs approach risk, compliance and reporting processes is the Financial Information Unit’s (FIU’s) Resolution No. 30-E/2017. The resolution was the FIU’s first regulatory step toward a risk-based approach for preventing money laundering and combating the financing of terrorism. Before the resolution, FIs – as well as all other obliged subjects under Anti-money Laundering Law No. 25,246 – had to comply with a formal compliance approach that obstructed the development of technological financial services. Along with the resolution, the Argentine Central Bank (ACB) has issued several regulations, including risk management guidelines and reporting obligations regarding the use of new technologies for the provision of financial services.
Stott: In the UK, the first enforcement investigations concerning individuals covered by the SMCR are now being concluded. The introduction of the SMCR has reinforced awareness of the risks associated with particular business activities. It has encouraged individuals to take a step back and consider the risks associated with areas or activities for which they are responsible and to take, and clearly document, the steps they have taken to minimise those risks.
FW: How important is it for FIs to cultivate a robust compliance and risk management culture across the organisation? What strategies can be deployed to take this process well beyond a box-ticking exercise?
Lipworth: Culture has been a focus for a number of years. We all now understand that a strong culture of ethics and compliance is the foundation of a robust risk management programme. Of course, embedding this culture and making changes is hard and requires effort and persistence, particularly when culture is a nebulous concept and the FCA does not provide clear and specific rules about it. Key strategies include setting the ‘tone from the top’, translating this into easily understood business practices and supporting the right behaviours through performance management, employee development and reward programmes. Tone from the top is, of course, a key ingredient of the appropriate prevention procedures for both the UK Bribery Act and the new failure to prevent facilitation of the tax evasion offence. The task is to translate this tone into business practices that drive how business decisions are made, how the firm responds to events, how individuals should behave and how issues are examined in an open way.
Wong: Having a robust compliance and risk management culture is one of the first principles of operational risk management. Effective corporate governance will enhance an organisation’s ability to access cheaper capital resources, safeguard against excessive risk-taking, actively promote the entity’s value in the market and sustain its development. Some suggested strategies which FIs might deploy include: applying the 11 fundamental principles of sound management of operational risk in Basel II, emphasising the supervising role and responsibilities of the board of directors and senior management, implementing a corporate culture which provides appropriate standards and incentives for professional and responsible behaviour, and enhancing internal cooperation to process organisational information through human and electronic systems.
Stott: Cultivating and maintaining a strong compliance and risk management culture can prevent breaches from occurring or, failing that, provide mitigation in the event of enforcement action taken by regulators. Which strategies will be appropriate is heavily fact dependent, and regulators expect each FI to look carefully at its activities in order to decide how best to give compliance and risk management due prominence. However, one key theme arising from enforcement actions where regulators have found weaknesses in compliance and risk management arrangements is communication. Regulators have clearly indicated that they do not regard compliance to be the sole responsibility of the second and third lines of defence and that they expect decisions about whether particular conduct is in line with regulatory obligations to be taken in real time by those in the business, involving their colleagues from compliance and other functions where necessary. In practice, simple measures, such as co-locating members of the compliance function with colleagues on trading floors, have been useful first steps to demonstrating a commitment to a robust compliance and risk management culture.
Diehl: A robust compliance and risk management culture across FIs is crucial in the context of digital transformation. As a consequence of developments in the way financial services are being offered, FIs are now becoming exposed to new challenges that require an interdisciplinary approach. It is a well-known fact that even the most secure technological framework will not be enough to prevent risks if the human factor does not meet the necessary level of sophistication. Therefore, Argentine regulatory authorities have requested FIs actively train their employees on risk management strategies. FIs are currently modifying their processes beyond the classical box-ticking exercise into more robust and dynamic strategies involving, among others, a multi-sector approach, and implementing new tools and methodologies to assess risks associated with the new challenges.
Brechan: A robust culture for compliance and risk management is vital. As there are many business units within FIs that have contact with customers, it is crucial that all relevant information is pooled and made accessible to relevant personnel. Politicians and regulators expect FIs to have updated customer information, to have adequate risk management policies which ensure that no uncalculated risk is taken on, that risk is priced correctly to ensure economic stability and that all compliance requirements are being adhered to. The use of FinTech, either for outsourcing or to digitalise internal processes, is important in order for personnel to see the bigger picture. However, outsourcing may encounter issues with respect to both risk management and regulatory approval and understanding – especially since there is a regulatory requirement for FIs to maintain sufficient expertise internally in order to monitor and take back outsourced operations.
FW: Generally speaking, is there often confusion about exactly where compliance and risk should sit within the organisational structure? Do you believe more needs to be done when it comes to assigning roles and responsibilities, defining remits and demanding accountability?
Wong: There is no doubt that the external risk and compliance environment faced by FIs is becoming more complex by the day. Some FIs in Vietnam have already placed risk management closer to the centre of their strategic agenda, appointed a chief risk officer and are focused on creating a coordinated approach to risk. However, coordinating and understanding risk management, from an organisational perspective, remains highly challenging. Banks derive 70 to 90 percent of their income from loans, and therefore, most have been focusing on credit risk, instead of installing a comprehensive risk management framework.
Diehl: In general, FIs demonstrate a clear vision as to where compliance risk should sit within an organisational structure. Nevertheless, as business operations become more complex and dynamic, new strategies must be developed in order to match the need for better risk management. It is clear that new roles and responsibilities will need to be implemented as the market develops. In several cases, FIs are redefining their structures to face the coming challenges. A more complex and cross-functional distribution of roles would be essential to such ends.
Brechan: Risk will invariably need to relate to operational questions and can be more integrated into the FI’s front line. Compliance should only come in the second line as a monitoring element.
Stott: For many FIs in the UK, implementing the SMCR has proven to be a useful exercise as it has encouraged them to re-evaluate how the various constituent elements of their business activities and functions fit together. It has prompted some FIs to undertake broader reviews of their governance arrangements. In some cases, these have led to risk and compliance functions being given greater prominence or resources within FIs.
Lipworth: A common arrangement is to make the compliance team a specialist part of the legal department. This facilitates synergies and the sharing of legal and regulatory experience. Legal and compliance can work on cases jointly, but there can be an unclear separation of roles. Compliance also sometimes sits within the risk function, but more frequently is a standalone function. This has the effect of significantly raising its profile and often the head of compliance will report directly to the CEO or the board. This can help to ensure that compliance is, and is seen to be, more independent. Whichever model is preferred, firms need to ensure that their compliance function is not acting simply as an adviser, but is putting more emphasis on active risk management and monitoring. In practice, it means expanding beyond offering advice on statutory rules, regulations and laws, and becoming an active co-owner of risks, to provide an independent oversight of the control framework.
FW: To what extent should employees be encouraged to ask questions of direct managers, human resources or the legal team so that potential risks can be identified early and serious issues avoided?
Brechan: To better understand the risk elements of a specific case, employees will need to ask questions to those who come in direct contact with customers. Then questions should be asked of the FI’s HR and legal departments to consider if there are any systemic risks involved, both with respect to the customer and the FI. The legal department can also assist in considering if there are any legal implications for a specific case, typically with respect to customer contracts, corporate structure and security. Risk is generally fact-based, and having the correct information will mean that risk elements are addressed and evaluated in relation to the risk appetite of the FI.
Lipworth: It is important to foster a culture in which it is business as usual for employees to express their concerns and be engaged in addressing them. The act of speaking up and others listening needs to happen before there is a need for whistleblowing; it is about getting ahead of the slippery slope. An organisation can empower individuals through training, but in a group dynamic we tend to change our behaviour and become vulnerable to situations and influence. It is important that firms support a culture of speaking up by flattening hierarchy and reducing power differentials. They also need to humanise the process by making sure that the compliance officer, general counsel and head of HR are accessible and approachable. It is also about developing managers so that they are really able to hear and act when they are told bad or difficult news.
Diehl: It is essential to provide agile communication channels and incentives to enable employees to ask questions of direct managers, human resources and legal teams, as well as other relevant departments in order to avoid serious issues and to allow potential risks to be identified that may otherwise remain undetected. In-house risk management and compliance training are some of the most important tasks on which FIs will have to focus. In several cases, such training is specifically required by Argentine regulatory authorities. Moreover, feedback from employees in connection with certain strategies should also be encouraged.
Wong: Employees should definitely be encouraged to ask questions as an organisation’s risk culture is very important. A sound risk culture promotes appropriate risk-taking and management of those risks. A strong risk culture means that employees understand and identify with an organisation’s mission, vision and core values. Boundaries are understood and employees can openly discuss and challenge risks taken to achieve the organisation’s strategic goals. The board, executive leaders and middle management should encourage open communication between employees and the expression of different points of view.
FW: Are you seeing more FIs apply data analytics to help them meet their risk management and compliance obligations? What benefits can technological innovations offer?
Lipworth: Firms process huge numbers of transactions and communications every day, and this produces huge volumes of information that live in silos within the firm. Data analytics tools can crunch massive data volumes and detect patterns and irregularities, allowing firms to proactively investigate risk events and behaviours and take corrective action. As use of these tools expands, firms will need to think carefully about broader issues around governance, controls and standards.
Diehl: FIs are applying data analytics for various purposes, with risk management and compliance two of the main ones. Technological innovations are currently allowing FIs to increase quality and widen the scope of the products and services they provide to customers, while also optimising the efficiency and productivity of internal processes. By using new technological tools, FIs are developing better credit scoring methods and user experience through electronic channels. These innovations also allow FIs to migrate from the traditional brick and mortar branch to a digital environment in which customers can perform the majority of operations through electronic means. The range of benefits that technology can offer to the financial services industry is virtually limitless.
Stott: Regulators expect FIs to apply data analytics, and indeed it is necessary for them to do so in order to examine the vast quantities of data they hold. Regulators have been clear, however, that technology is not a substitute for the exercise of human judgment. For example, in the financial crime context, the FCA has recently confirmed that it expects individuals within FIs to “check the [electronic] checkers”. FIs are required to identify and report suspicious or unusual patterns of payments or trading behaviour within short timescales. Technology can help them examine large quantities of complex data quickly and efficiently and to rule out irrelevant material, but regulators still expect decisions about whether and what to escalate or report to be taken by appropriately experienced staff.
Wong: In Vietnam, data analytics, such as digital data and Big Data, are playing an important role in banks and FIs. Digital data can generate revenue and create new application ecosystems, services and digital products. Big Data is able to exploit certain data, which can bring significant competitive advantages and efficiencies for banks and FIs. These data analytics can drive business volume to stress control frameworks and help banks and FIs meet their risk management and compliance obligations.
Brechan: There has been an increased use of analytical data and technology, particularly in risk management. For compliance, it is often more a question of ‘translating’ compliance requirements into a language understandable by business people. Automated processes where customers render all relevant information for risk and compliance online to the FIs increase the availability of information, awareness of the issues at hand, the use of the available instruments and adherence to compliance requirements.
FW: To what extent can technology enhance collaboration between the different functions within an FI – departments or groups which may have inadvertently become entrenched in a silo-based mentality?
Diehl: Digital transformation not only enhances collaboration between different departments within an FI, it demands collaboration. There are currently several tools and organisational methods to enable a more interconnected and collaborative environment within an FI’s structure. As technology impacts on every process and activity of the financial services industry, silo-based mentalities should be identified and swiftly remodelled in order to avoid unnecessary flaws. Proper training and adequate allocation of responsibilities within each organisation will play key roles in building an efficient structure to meet future challenges.
Wong: The use of advanced tools has implications for broader process-level and organisational changes. In afflicted ‘silo-mentality’ departments or groups, messaging platforms have enabled employees to communicate more often and to self-organise with team members. It changes the very nature of their work, to become more project-based, rather than team or function-based. Messaging platforms help employees to communicate differently within teams but also across levels, roles and entire organisations.
Brechan: FIs using software like Facebook Workplace have employees going out of their silos – though such technology and communication platforms are prohibited from being used to discuss specific business cases, such as risk or compliance. These new communication platforms are breaking down barriers and are replacing the ‘coffee machine’ or the ‘water cooler’ as a means of exchanging knowledge.
Lipworth: Collaboration technologies can aid efficiency, improve quality and increase productivity. Social workflow platforms can provide a collaborative environment which guides people through an optimised and standardised work plan, with roles, tasks and templates laid out in advance. Team members can then use the platform to allocate work, conduct discussions, share updates, review checklists and obtain approvals. Tagging, searching and messaging features make it easier to ask for help, locate documents and share best practices. But simply making collaboration technologies available is not enough. It is equally important to engage in the change management activities that shape, encourage and incentivise the desired collaborative behaviours.
FW: With numerous regulatory changes and increasing risk and volatility impacting the financial environment, to what extent should FIs consider redesigning their operating models to more effectively control costs and improve efficiency?
Wong: In the current environment of increased regulation, market volatility, increased risk, fierce competition, tighter margins, reduced returns and changing client expectations, it essential that banks continue to rethink and adapt their operating models. Banks need to process a larger volume of information at a quicker pace, with ever-changing demands relating to client, regulatory and financial data. Increased importance is placed on data, client information and reporting with zero tolerance for errors and delays. Together with digitalisation and increasingly sophisticated clients, this has placed additional burdens on banks, and so they must look at innovative ways to differentiate themselves to successfully overcome obstacles.
Brechan: Scandinavian FIs are at the forefront of developing alternative and automated services to accommodate the changing environment in which they operate. The latest move in Norway to merge the automated transfer system developed by DNB, in which all competitors have been invited to participate, called VIPPS, with the payment transfer system commonly used in Norway, which is cheaper and faster than VISA or MasterCard, and the digital signature called BankID, has received regulatory approval from the competition regulator and is awaiting approval from the financial regulator. These services have become so popular that their names have been accepted as verbs: SWISH in Sweden and VIPPS in Norway.
Moreno: In Argentina, regulatory entities are migrating to a risk-based approach that allows FIs to choose from a wider range of options to meet their compliance obligations. FIs should analyse the opportunities provided by regulatory changes and prepare their operating models for upcoming challenges posed by the market. Several FIs in Argentina are currently working to identify the changes needed to their models to improve their efficiency. The market is becoming more complex and traditional models are proving to be outdated in various aspects.
FW: What strategies are FIs adopting to tailor their risk management and operating models to reflect the current business landscape?
Diehl: Among other strategies, FIs in Argentina are conducting fluent dialogues with regulatory authorities which, as in the case of the ACB, have created specific working groups to suggest changes in the current regulatory framework regarding the use of technology. This allows FIs to take a closer look at the regulator’s view of upcoming compliance challenges. With the ACB recently issuing several regulations allowing FIs to operate with a wider range of technological tools, FIs are dedicating greater resources in their digital strategy departments to adapt their models to the current business landscape.
Brechan: Automation is a frequently-used strategy. Typically, it is used for standardised lending products, like unsecured loans, where most banks have automated credit approvals for online applications up to amounts of €50,000. In order to combat new services like ApplePay or SamsungPay, banks have asked service providers to increase the services available in shop terminals, at point of sale. In Norway, this has led to cash very seldom being used, to the extent that cash payments are regarded as tax-evasive behaviour and all payment for services in excess of €1000 having to be made between bank accounts.
Wong: There are a number of strategic areas where many financial industry leaders across the region are concentrating their efforts. One area is business alignment. The basic premise is to exit business lines that have high costs and low margins, and move into lines that are inherently more cost-effective and profitable. Another is channel optimisation. Leaders must assess the various ways customers interact with a bank or FI to create a cost-effective combination that is adapted to each organisation’s specific customer base. Process cost is also significant. The opportunity to improve in this area is often underestimated by banks and FIs because it takes a non-traditional view of business processes.
FW: What essential advice would you offer to FIs on adjusting their internal frameworks and processes to achieve higher levels of risk management and governance?
Brechan: Automation is the way forward, either directly toward customers as online service requirements or as a means of internal risk evaluation process and compliance checks. To the extent the different systems of an FI are able to integrate, compliance and sanctions issues can be readily addressed. Risk assessments of customers made by third parties can be readily integrated in online services, though fine-tuning pricing may need some personal subjective input. The major Scandinavian FIs are cooperating to establish a joint venture to perform their Know Your Customer (KYC) checks, as the Scandinavian countries share a common legal structure with respect to personal data and corporate structures.
Wong: An FI’s internal framework should be developed, implemented and fully integrated into its overall risk management processes. That means that the board of directors and the FI’s management should understand the nature and complexity of the risks inherent in the bank products, services and activities. The framework should be appropriately integrated into the risk management processes across all levels of the organisation, as well as into new business initiatives, products, activities, processes and systems. The framework’s documentation should clearly identify the governance structures, including reporting lines and accountability.
Lipworth: FI’s need to build a strong risk management culture. The detection, assessment and mitigation of risk must become part of the daily job of all staff, not only those in risk functions.
Diehl: The financial services industry in Argentina is changing toward an electronic environment. Financial services are evolving as to how they are provided by FIs and requested by clients. The time has come for FIs to rethink traditional structures, frameworks and processes, in order to be able to have an agile and more dynamic approach to upcoming challenges. FIs need to create collaborative environments to allow fluent and consistent connections between their digital strategy departments and risk management and compliance. Data analytics and artificial intelligence (AI) will have a great impact on risk management and will also provide more cost-effective performance.
FW: Looking ahead, how do you expect the risks and compliance challenges for FIs to unfold and evolve over the coming years? What factors will separate those organisations that can successfully meet their obligations from those that fall short?
Stott: Regulatory focus on whether FIs maintain an appropriate culture, which is measured largely by reference to the importance attached to compliance, risk management and governance, is not likely to diminish. Although the risks they are guarding against will often be complex, FIs’ frameworks and processes do not necessarily have to be. They are more likely to be successful in detecting and addressing risks and to endure changes in key personnel and regulatory priorities if they are simple enough to be embedded into day-to-day operations without creating layers of additional bureaucracy, and if the rationale for them, including the possibility of personal liability for regulatory breaches, is effectively communicated.
Wong: When banks and FIs identify data of great value, they must consider the data assets of the organisation. In other words, data must be treated like any other organisational asset, which needs to be taken care of and have its security ensured. The sensitivity and potential value of the data makes FIs a prime target for cyber criminals. These attacks can hinder an FI’s ability to maintain compliance and can cripple the business in the process. Data privacy for businesses in the financial sector requires FIs to be responsible for a wealth of financial and personally identifiable information that requires special attention. In addition to controlling compliance costs in a regulatory context, FIs should consider the repercussions in non-compliant scenarios.
Lipworth: We have not yet reached peak regulation, so there will be a steady diet of issues to deal with over the next few years. This will be made more difficult because today’s consumers and businesses have ever-rising expectations of near-instantaneous service and a frictionless on-boarding process. Also, risk and compliance teams are likely to continue to confront significant IT and data constraints, with a patchwork of different systems struggling to provide a comprehensive picture and where both access to data and data quality remains poor.
Diehl: The future of risk and compliance challenges will undoubtedly be connected to technological innovations and business and operative environments are likely to develop around them. The development of a wider range of products and services provided through electronic means, along with the imminent eruption of AI, will definitely bring new risk and compliance challenges for FIs. Prevention and mitigation of risk will depend on an ability to evolve with challenges and identify key aspects in which a company’s resources can be invested. Additionally, a multisectorial approach from the different departments of each FI will play an important role in the way FIs organise internal processes.
Brechan: The expectations of regulators and customers of FIs will lead to an increasing requirement for automation of services and internal processes. Monitoring such digital processes will be the main challenge in the coming years. I also think the use of common services not directly related to traditional services rendered by FIs will be outsourced to FinTech companies or joint ventures, with FIs concentrating on their core businesses.
Chris Stott is a lawyer in Clifford Chance's litigation and dispute resolution practice in London. In addition to advising corporate and individual clients on conducting their own investigations and responding to those pursued by enforcement authorities in the UK and worldwide, Mr Stott advises on and oversees reviews of clients' risk management, governance and financial crime compliance arrangements. He has been seconded to Clifford Chance's Hong Kong office and to an international bank to advise on the implementation of UK individual accountability regimes. He can be contacted on +44 (0)20 7006 4231 or by email: firstname.lastname@example.org.
Peter Brechan has more than 30 years of experience in the financial sector. He specialises in finance, as well as in corporate and regulatory matters. He works within all areas related to lending and other forms of financing, but has lately focused more on product development, derivatives, compliance and risk management. He is instructed by lenders, sponsors, arrangers and borrowers, but is also adviser to boards within the financial sector. He is ranked within his areas of expertise in all representative publications, such as Legal 500, Chambers Europe, Euromoney’s Expert Guide and IFLR1000. He can be contacted on +47 922 84 444 or by email: email@example.com.
Claire Lipworth is a partner in the London office of Hogan Lovells, where she specialises in white-collar defence, internal and external investigations and compliance. She began her career at Peters & Peters, where she was a partner from 1999 to 2009, before joining the Financial Conduct Authority (FCA) where she served as chief criminal counsel. She can be contacted on +44 (0)20 7296 2982 or by email: firstname.lastname@example.org.
Juan M. Diehl Moreno is a partner at Marval, O’Farrell & Mairal in Buenos Aires, Argentina, with particular focus on banking and corporate finance. He has been increasingly active providing a full range of strategic legal advice to financial institutions and FinTech innovators, while developing and adopting products and services such as crowdfunding, e-payment platforms, cryptocurrencies and digital banking. He can be contacted on +54 (11) 4310 0126 or by email: email@example.com.
Kent Wong is a partner at VCI Legal, a leading national law firm in Vietnam. He heads the banking and finance/capital markets team. He represents major Korean and Vietnamese financial institutions, as well as foreign clients with business interests in Vietnam and Korea. Mr Wong advises on a broad range of banking and corporate matters and has acted on a variety of international finance transactions, including renewable energy and ADB infrastructure projects, syndicated lending, acquisition financing and restructuring. He can be contacted on +84 28 3827 2029 or by email: firstname.lastname@example.org.
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