International Banking and Finance law
Name
Course
Date
Can the application of technology in the banking sector conflict with the exercise of manual or judgmental intervention of regulators
Introduction
In the modern world, technology is increasingly being used in the banking sector by regulatory authorities as well as regulated institutions. Technology has played a key role in creating an efficient banking system that can respond sufficiently to the needs of a growing economy. The emergence of advanced technologies has resulted in the development of new technology-oriented business models in the financial industry.[1]In addition, these technologies have been used to support compliance with financial regulation and financial supervision.[2] New technologies such as SupTech and RegTech have enhanced supervisory and compliance processes which were previously manual and inefficient.[3] Financial technology, also known as Fintech, has played an important role in widening the range of financial services, increasing efficiency in delivering financial services, promoting financial inclusion, and increasing competition.
The use of technology in the financial sector has greatly enhanced the ability to improve existing tools in the banking sector as well as the ability to develop considerably better tools. The technology authorities use to enhance supervisory capabilities is called SupTech, while institutions use technology to meet their regulatory requirements is called RegTech. Regulated institutions and authorities are increasingly using these new technologies to help them meet the increased regulatory requirements established after the financial crisis of 2008. While new technologies have enhanced the process of supervision and compliance in the banking sector, there are a number of challenges linked to the use of these technologies. However, technology in the banking sector does not conflict with the manual interventions of regulators with regards to issues like authorisations, the detection of financial crime, and the identification of mis-selling practices. Technological advancements such as RegTech and SupTech actually enhance the ability of regulators to conduct their work and play an integral role in addressing the challenges posed by manual information and processes.
Application of Technology in the Banking Sector
In today’s banking sector, both finance and financial regulation are increasingly being digitised. Digital financial services are compelling central banks and regulators to redefine their approaches to banking regulation and supervision.[4] The new approach by regulators involves leveraging data, adopting new technologies, and becoming resilient while simultaneously delivering regulatory services.[5] This trend has been adopted due to the increasing availability of data as well as the development of new kinds of data analytics such as artificial intelligence. In the new digital economy, regulators are compelled to step up to stay relevant and continue to carry out their responsibility of promoting a trustworthy financial system, facilitating market competition, and protecting end customers.[6]
The work of central banks and regulators typically encompasses the supervision of the financial sector to ensure stability, regulating the operation of payments clearing and settlement systems, as well as controlling foreign exchange reserves.[7] The introduction of new technology to the banking sector has compelled regulators and central banks to take on the additional responsibility of preventing loopholes in the current supervisory framework and addressing new emerging risks in the banking sector.[8]
Financial firms are increasingly interested in using technology to more effectively and efficiently meet regulatory and compliance standards (known as RegTech), while the public sector is interested in using technology for regulatory, supervisory, and oversight purposes (referred to as SupTech).[9] RegTech and SupTech solutions are emerging for a variety of regulatory focus areas, including regulatory change tracking, fraud detection, know-your-customer, counter-terrorist financing, conduct, and prudential risk management, systematised regulatory reporting, and associated auditable record-keeping.[10] Certain SupTech technologies allow regulators to create and transmit machine-readable and machine-executable regulations to their regulated firms, potentially resulting in more automated regulatory compliance, cheaper costs, and improved regulatory reporting consistency.[11] Other SupTech solutions aim to provide real-time risk alerts, allowing supervisory teams to shift their focus to preventive rather than reactive oversight, perhaps enhancing resilience.[12]
Digitisation has been promoted due to its potential to make operations better, faster, and cheaper. Low-cost computing and data storage has become possible thanks to technological advancements. As data storage costs have dropped, computing efficiency has increased dramatically. In 1980, data that would have taken a room full of tape or hard drives may now be stored on a micro secure digital (SD) card.[13] As the cost of data storage has decreased from USD 0.11 per gigabyte in 2009 to USD 0.02 in 2020, the amount of data created globally has grown dramatically, reaching an anticipated 48 zettabytes (48 trillion gigabytes) by 2020.[14] With advancements in artificial intelligence (AI) and machine learning, the capacity to handle such data quickly has also increased.[15] SupTech and RegTech tools have played an important role in promoting financial stability. For instance, authorities can use SupTech surveillance and analytical capabilities, and oversight.[16] In addition to this, SupTech can help authorities generate real-time indicators of risk to enable predictive and judgment-based policymaking and supervision.[17] In the case of regulated institutions, RegTech plays an important role in improving risk management capabilities as well as compliance outcomes.[18]RegTech has been described as an important technology in the fight against financial crimes. This is crucial because financial crimes pose a significant issue with regards to the development, integrity, and stability of financial services as well as society in general. Some of the financial crimes that RegTech helps address include terrorist financing, rogue trading, money laundering, cyber fraud, and bribery, and corruption. RegTech is extremely important to financial institutions today because financial crimes have increased in regularity and sophistication due to technological advancement. In addition, RegTech is useful in terms of generating new insights into the business for enhanced decision-making.
Previously financial crimes would go undetected for long periods of time and would only be detected after a significant amount of damage had occurred. For instance, in the year 2017, around US$223.07 billion worth of suspicious transactions with and from sources in Russia and Azerbaijan was discovered after an investigation was launched into the Estonia branch of Danske Bank.[19] This particular incident was described as the biggest money-laundering scandal in Europe and one of the biggest in the world. Some of the reasons why such financial crimes were difficult to detect include weak controls and governance, high dependencies on human judgment as well as insufficient resources for monitoring. RegTech has played an important role in helping to address these financial crimes and is described as the most advanced weaponry in the arsenal against financial crimes. Banks in the United States that make use of advanced analytics have experienced a twenty-five percent reduction in false positives and a thirty percent reduction in annual labor.
The COVID-19 pandemic has accelerated the use of digital technology in the financial sector, which was already underway. The use of technology in the financial sector has helped solve regulatory and compliance requirements in a more efficient and effective manner. Financial technology can be used for both regulatory and compliance requirements as well as for supervisory and oversight purposes. This has greatly helped reduce manual processes and increase efficiency.[20] For many years, data management in the financial sector was mostly manual. Manual data collection created operational and security risks as well as file size restrictions.[21] Data validation by financial authorities had to take place manually. In addition to this, extraction, transformation, and loading of data were also carried out manually.[22] Further, static reports had to be updated manually. The automation of certain paper-based and manual processes enabled many financial authorities to address some of these manual inefficiencies.[23] Supervisory technology has enabled financial institutions to digitise reporting and regulatory processes, which has translated to greater efficiency in terms of monitoring risk and compliance in financial institutions.[24] Supervisory technology is primarily used in data collection and data analytics.
Many jurisdictions have adopted policies that promote the provision of digital banking services. For instance, some policies have enabled financial institutions to identify and verify customers without their physical presence.[25] In jurisdictions such as Singapore, Hong Kong, and India, residents are able to use a unique electronic key to verify their identity in all kinds of transactions.[26] Jurisdictions such as Hong Kong and Singapore have also put in place policies that promote the establishment of digital banks.[27]
Benefits Of Using Technology in Supervisory and Compliance Processes
There are a number of benefits of using technology in supervisory processes in the financial sector. These benefits include reduced costs, increased efficiency as well as advanced capabilities.[28] SupTech has been shown to improve supervisory capabilities by enriching the intelligibility and interoperability of data, improving surveillance and assessment of risks in real-time, providing predictive analysis, and reducing overall cost.[29]
While the use of technology has greatly enhanced supervision and helped reduce compliance costs, there are a number of existing challenges. The lack of transparency in some of the data analytics applications has necessitated the use of human intervention in the supervisory process, especially with regards to investigating the results of analyses and deciding on a course of action.[30] There is also the risk of market participants adjusting their behaviour in order to avoid compliance. Other risks associated with SupTech and RegTech tools include reputational risk, cyber risk and data quality issues.[31]
According to statistics from the United Nations, of the two trillion dollars laundered each year globally, less than one per cent is detected by authorities.[32] The use of analogue methods to counter money laundering has been shown to be ineffective in detecting most digital-age financial crime.[33] Jo Barefoot argues that analogue era anti-money laundering rules cause financial institutions to unfairly lock out law-abiding customers along with criminals due to the deficiency of finely-tuned data.[34] New technologies such as artificial intelligence and big data can help address this issue by showing patterns of transactions that can identify the flow of illicit funds. As such, it is important for regulators in the banking industry to embrace new technologies that will enable them to identify financial crimes and mis-selling practices.
New technologies can play an important role in significantly reducing compliance costs. It is estimated that the global banking industry spends one hundred billion dollars on compliance alone.[35] This particular challenge weakens the competitiveness of small banks, deters new entrants into the market and makes financial services unattainable for millions of people who wish to get banking services.
Risks and challenges of using technology in the banking sector
There are a number of risks and challenges associated with the use of technology in the banking sector. One of the challenges facing authorities and regulated institutions is data completeness and data quality.[36]Another challenge associated with using technology in the banking sector is cyber risk and data security.[37] The increasing use of digital technologies and enhanced interconnectedness of regulated institutions and external parties like technology vendors has increased cyber risks and vulnerabilities.[38] The use of novel technologies has magnified financial stability risks since they have increased the attack surface should a cyber-incident occur.[39]
A significant risk posed by the use of technology in the banking sector is the loss of privacy and data security for consumers.[40] Many consumers are concerned that their data might be accessed by unauthorised people such as hackers and criminals.[41] Identity theft is also a common concern regarding the use of technology in the banking sector. According to a 2016 report by the Insurance Information Institute, sixteen billion dollars was stolen from more than fifteen million customers via identity theft.[42] Stolen data is often sold on the dark web, putting the privacy of millions of people across the globe in jeopardy.[43] There is also the emerging risk of frauds and scams that affect certain vulnerable groups such as senior citizens, people with disabilities, and people who speak English as a second language.[44]
Another risk regarding the use of technology in the banking sector revolves around data rights. It is unclear how and whether consumers can consent to third parties accessing their bank account data in order to carry out tasks for them.[45] There is also the concern that technology in the banking sector can be used to promote discriminatory practices. Lenders could use the technology to promote discriminatory practices that produce statistical outcomes that are disproportionately adverse to some people based on factors like national origin, ethnicity, race, sexual orientation, religion, receipt of public assistance, and sex.[46]
While technology has played an essential role in helping investigators and prosecutors prevent and detect financial crimes, it has also helped criminals carry out their fraudulent activities more efficiently. New companies that offer an alternative to traditional banking provide a unique opportunity for criminals to launder their money in plain sight.[47] Faster payments have also enabled criminals to transfer illicit funds at a much quicker rate than before and on a global scale.[48] Today’s criminals are targeting financial institutions with new technologies that are potentially less secure.[49] New businesses must maintain strict compliance procedures when taking on customers and implement effective anti-money laundering and Know Your Customer processes in their operations.[50] Fortunately, technology can also be used by financial institutions to curb criminal activities. For instance, artificial intelligence and machine learning systems can be used to detect complex patterns of criminal behaviour.[51] Recent advancements in Artificial Intelligence have enabled machines to surpass humans in terms of decision-making in various areas.[52] In the future, we can expect artificial intelligence to be used together with the cloud to achieve greater security, efficiency and accuracy. Businesses in all sectors ought to review their internal processes with the objective of protecting their services to make sure that they are not exploited.[53] Businesses that fail to prioritise technology face the risk of being vulnerable to disruptive companies as well as criminals.
Cyber security is an issue that cuts across all sectors, including traditional financial services providers, Fintech as well as big technological companies. The digital transformation of finance has created greater and unprecedented cyber risks. Due to the increase in interconnectivity, the attack surface has broadened significantly.[54] This situation increases operational risks because a larger number of separate organisations may be tasked with producing a single product or service, thereby creating a large web of operational dependency.[55] Simultaneously, certain core services have become more concentrated, thereby creating the potential that single points of failure could result in widespread disruption.[56]
Does the application of technology in the banking sector conflict with the exercise of manual or judgmental intervention of regulators?
Research suggests that can actually play an important role in assisting regulators as opposed to hampering their operations. For instance, new technologies have been shown to play an important role in preventing money laundering. According to a study by Europol, banks across the world spend two hundred and sixty million dollars annually to prevent financial crimes.[57] It is estimated that two trillion dollars is laundered via financial institutions each year.[58] New technology has played an important role in enabling compliance professionals to prevent, detect and also recover the money linked to criminal activity.
Technological innovations such as Artificial Intelligence, machine learning and big data have enhanced the process of detecting financial crime. Slow and manual-orientated processes in the banking sector are increasingly being replaced by machine learning and artificial intelligence.[59] This is because these technological innovations can scan larger quantities of data and a faster rate compared to humans. Trigger alerts in the banking sector, such as a transaction being conducted outside the account holder’s country of residence or a transaction exceeding a certain value, present a number of challenges. For example, these trigger alerts have the tendency to produce false positives.[60] All these false triggers alerts traditionally required a human being to review in order to alleviate any concerns. However, the adoption of Artificial Intelligence has greatly enhanced efficiency in this particular process.[61] Artificial Intelligence can be used to identify patterns of transactions, behaviours, and anomalies at a faster rate compared to humans.[62] This allows compliance professionals to spend time on other aspects of the process such as result analysis, investigating the cause of the issue as well as comparing their findings with other financial institutions or authorities.
In addition to aiding in transaction monitoring, technology can play an important role in establishing connections and detecting patterns.[63] Big data has enabled financial institutions to ‘map out’ strings of transactions and determine the original sources of illicit activity more efficiently.[64] Big data has enabled financial institutions to easily trail illicit gains from criminal activities, establish which parties are involved in the laundering process, and share useful information with other organisations and authorities to prevent the flow of illicit funds. Distributed Ledger Technology is another technology that can play an essential role in improving processes in the banking sector. Distributed ledger technology is essentially a set of technological infrastructure and protocols that enable the simultaneous access, validation, and updating of records in distributed ledgers.[65] Distributed ledger technology operates on a computer network spanning over several organisations or geographical locations.[66] Distributed ledger technology uses cryptography to store data securely. In addition to this, distributed ledger technology has cryptographic signatures and keys that allow access to authorised users only.[67] Distributed ledger technology also generates an immutable database that stores data permanently as well as updates.[68]
Recommendations
Finance is an essential element to healthy economies and societies. An efficient and effective financial sector can play an integral role in promoting inclusiveness, fairness and economic stability. In contrast, a failing financial system is bound to result in human suffering such as the one witnessed in the Great Depression or the 2008 financial crisis.[69] Policies and regulations play an important role in ensuring financial stability within a particular jurisdiction. The four primary goals of regulations include: promoting a stable financial system, promoting customer protection, promoting financial inclusion and deterring financial crime and money laundering.[70] Unfortunately, regulations have not been entirely successful at achieving these goals. This is because, despite the existence of regulations, consumers are still harmed by financial services, millions of people are still unable to access financial services, and financial crime is still rampant.[71] One of the major challenges that prevents regulators from achieving these outlined goals is that they do not have enough information.[72] This challenge has been compounded by the fact that technology is advancing at a tremendous pace that is changing the banking industry.
Unfortunately, regulators are approaching these emerging trends in the banking industry with “analogue” era information, “linear” models and tools that were invented prior to the digital age.[73] The exponential increase in technological ability has proven to be a challenge for many players in the banking industry. In 2019, Mark Carney, the governor of the Bank of England, articulated the need to incorporate artificial intelligence in the process of financial regulation.[74] The governor stated that the bank received an overwhelming sixty five billion pieces of information each year from companies under its jurisdiction which proved to be a significant challenge for the bank’s supervisors.[75] This revelation shows that regulators must digitise at the same rate as information in the financial system digitises. Two innovative technologies that can help regulators are RegTech and SupTech which have the potential to enhance the current performance of the regulatory system which would have been virtually impossible using analogue technology. RegTech is used in the compliance efforts of regulated institutions, while SupTech is used by supervisory authorities such as the ones that oversee financial institutions such as banks.[76]
The regulatory technologies that are in place currently were mostly designed in the pre-digital age when information and processes typically involved paper.[77] This means that some of these regulatory technologies are very old and practically obsolete in the digital age. This type of information is expensive to access for regulators. This means that regulators have to struggle when accessing information contained in analog forms such as reports, files, and databases.[78] The disadvantage for regulators in that analogue information cannot be assessed quickly and comprehensively. Many regulatory frameworks are reliant on periodic reports which can delay information for long durations of time.[79] In addition to this, regulatory systems in various jurisdictions rely on partial information and often sample records in an attempt to detect risk and noncompliance. The emergence of information and technology in the modern banking environment has greatly increased the risk of regulatory failure.[80] It is recommended that manual systems of regulations should be eliminated entirely and the system should be transformed into one that is digitally-native. This means that the entire system should be designed using digital technology in order to eliminate the need to use analogue systems of information such as reports which are expensive, difficult to access and cumbersome. The most significant disadvantage of manual document filing is the amount of space it consumes. While it may not seem like a big concern at first, as your company grows, you’ll need to find a new means to store information. Otherwise, you may find yourself occupying space simply to accommodate the files. This is a huge headache that you don’t need. It detracts from your productivity.
Manual document filing entails putting your trust in the persons who will be managing the files. They can be destroyed, lost, or misplaced in a variety of ways. A fire or natural calamity might result in the loss of all of your client’s sensitive data. It may also result in the loss of clients who are dissatisfied with your mismanagement of their information.
Regulatory reporting is one area where cutting-edge technology can make a big difference. From source system data to report mapping and business rule automation to report production, the complete regulatory reporting process will most likely be automated in the future.[81] However, getting there will almost certainly be a difficult task that will take many years to complete. Rather than waiting for comprehensive transformation, companies could focus on important areas of the regulatory reporting process that are prepared for automation and cognitive intelligence now.[82] Organisations may lead in banking and securities, handle risks and opportunities, and challenge the status quo by embracing regulatory reporting’s complexity and exploiting these tools.[83]
Conclusion
The use of technology does not conflict with the exercise of manual or judgmental intervention of regulators in respect of matters such as authorisations, the detection of financial crime and the identification of mis-selling practices. In fact, application of technology greatly enhances the activities of compliance professionals and helps address the deficiencies of the manual process of regulatory bodies. New technologies such as SupTech and RegTech have significantly enhanced supervisory and compliance processes which were previously manual and inefficient. The global financial crisis of 2008 marked a turning point in the development of financial technology (FinTech) and regulatory technology (RegTech), separating previous periods from the current paradigm.
Financial crimes are growing more complex, technology-driven, and anonymous with each passing day. RegTech has the potential to assist financial institutions in adapting to the changing regulatory landscape by delivering technologically enhanced solutions that satisfy the ever-increasing compliance needs. Individuals, financial institutions, and regulatory agencies must all work together to create a RegTech ecosystem and platform-based architecture. And the sooner that happens, the simpler it will be to confront this global crisis before the entire financial ecosystem is irreparably damaged.
FinTech has now entered a period of fast growth, characterised by a proliferation of startups and other new entrants, such as IT and eCommerce enterprises, fragmenting the financial services sector. This new age brings new problems for regulators, emphasising why the rise of FinTech demands the development of RegTech in tandem. Regulators, in particular, must create a strong new framework that encourages innovation and market confidence, helped by the deployment of regulatory “sandboxes.” RegTech, which is currently in its second stage of development, is being utilised by both institutions and regulators to manage the growing complexity of compliance operations.
Disruptive technology innovation will continue to change financial systems in 2021, but Covid-19 will pose new vulnerabilities to the regulatory and supervisory regimes that safeguard them. Cryptocurrencies are compelling regulators and supervisors to choose sides, cyber risks are adding new dimensions to systemic risk, and digitalisation is bringing novel venues for financial crime and fraud to the fore. The proactive use of new technologies such as machine learning or distributed ledger technology (DLT) brings up unparalleled regulatory and supervisory options. RegTech and SupTech are emerging tools and frameworks that use Big Data to speed up risk-based reporting, monitor systemic risk, and oversee financial institutions. Central bankers are increasingly recognising that major change is required to take advantage of these growing opportunities: at the analytical, technological, and institutional levels. Technology used by authorities to enhance supervisory capabilities is known as SupTech while technology used by institutions to meet their regulatory requirements is called RegTech. Financial technology, also known as Fintech has played an important role in widening the range of financial services, increasing efficiency in delivery of financial services, promoting financial inclusion and increasing competition.
Studies show that many regulatory authorities still use manual information and processes when carrying out their supervisory mandate. Analogue information and processes have been criticised for being expensive and not easily accessible. Many regulators still rely on periodic reports which can delay information for long durations of time, sometimes lasting a whole year. Further, various regulatory systems rely on partial information and often sample records in an attempt to detect risk and noncompliance. The emergence of information and technology in the modern banking environment has significantly amplified the risk of regulatory failure. Recently, the governor of the Bank of England stated the need to incorporate artificial intelligence in the process of financial regulation. The governor argued that the Bank of England received sixty five billion pieces of information each year from companies under its jurisdiction which proved to be a significant and overwhelming challenge for the banks supervisors.
In addition to technology playing an important role in addressing the inefficiencies of the manual process, it can also help curb financial crimes. Technological developments such as Artificial Intelligence, machine learning and big data have greatly enhanced the process of detecting financial crime. Artificial Intelligence has been shown to have the capability of identifying patterns of transactions, behaviours and anomalies at a faster rate compared to humans allowing compliance professionals to spend time on other aspects of the process such as result analysis, investigating the cause of the issue and comparing their findings with other financial institutions or authorities. Big data on the other hand has enabled financial institutions to ‘map out’ strings of transactions and determine the original sources of illicit activity more efficiently making it possible to easily trail illicit gains from criminal activities, establish which parties are involved in the laundering process and be able to share useful information with other organisations and authorities in order to prevent further flow of illicit funds.
It is strongly recommended that manual systems of regulation should be phased out entirely, and the system should be transformed into one that is digitally-native. This means that the entire system should be designed using digital technology in order to eliminate the need to use analogue systems of information such as reports which are expensive, difficult to access and cumbersome. In addition to this, it is also recommended that efforts should be made to address the risks associated with the use of technology in the banking sector. These risks include: risk of fraud and scams, discriminatory and unfair use of data, compromised data security, loss of privacy as well as uses of data that are non-transparent to both consumers and regulators. Financial institution should seek to ensure that these concerns are addressed as they transition to a more digitised model of banking.
Bibliography
Accenture, “REGTECH the NEW WAR CRY against FINANCIAL CRIME” (2021) <https://www.accenture.com/_acnmedia/pdf-106/accenture-regtech-the-new-war-cry-against-financial-crime.pdf>
Barefoot J, “M-RCBG Associate Working Paper Series | No. 110 Regulation Innovation: Using Digital Technology to Protect and Benefit Financial Consumers” (2019) <https://www.hks.harvard.edu/sites/default/files/centers/mrcbg/working.papers/AWP_110_final.pdf> accessed December 22, 2021
——, “M-RCBG Associate Working Paper Series | No. 150 Digitizing Financial Regulation: Regtech as a Solution for Regulatory Inefficiency and Ineffectiveness” (2020) <https://www.hks.harvard.edu/sites/default/files/centers/mrcbg/files/AWP_150_final.pdf> accessed December 22, 2021
——, “M-RCBG Associate Working Paper Series | No. 151 Digital Technology Risks for Finance: Dangers Embedded in Fintech and Regtech” (2020) <https://www.hks.harvard.edu/sites/default/files/centers/mrcbg/files/AWP_151_final.pdf>
BIS Innovation Hub, “BIS Innovation Hub Work on Suptech and Regtech” [2021] www.bis.org <https://www.bis.org/about/bisih/topics/suptech_regtech.htm>
Broeders D and Prenio J, “Innovative Technology in Financial Supervision (Suptech) -the Experience of Early Users” (2018) <https://www.bis.org/fsi/publ/insights9.pdf>
Cœuré B, “Leveraging Technology to Support Supervision: Challenges and Collaborative Solutions Introductory Remarks” (BIS Innovation Hub 2020) <https://www.bis.org/speeches/sp200819.pdf> accessed December 21, 2021
Deloitte, “Automation of Regulatory Reporting in Banking and Securities” (Delloitte2021) <https://www2.deloitte.com/us/en/pages/regulatory/articles/automating-regulatory-reporting-banking-securities.html> accessed December 22, 2021
Ehrentraud J and Ocampo D, “Policy Responses to Fintech: A Cross-Country Overview” (2020) <https://www.bis.org/fsi/publ/insights23.pdf>
Feyen E and others, “BIS Papers No 117 Fintech and the Digital Transformation of Financial Services: Implications for Market Structure and Public Policy” (2021) <https://www.bis.org/publ/bppdf/bispap117.pdf>
Financial Stability Board, “The Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions Market Developments and Financial Stability Implications” (2020) <https://www.fsb.org/wp-content/uploads/P091020.pdf>
Maria V, “Is Technology Helping or Hindering Our Fight against Financial Crime?” (ForbesJanuary 16, 2019) <https://www.forbes.com/sites/vishalmarria/2019/01/16/is-technology-helping-or-hindering-our-fight-against-financial-crime/?sh=5e03d453312e> accessed December 22, 2021
McDowell H, “Banks Spent close to $100 Billion on Compliance Last Year – the TRADE” (www.the trade news.comApril 13, 2017) <https://www.thetradenews.com/banks-spent-close-to-100-billion-on-compliance-last-year/> accessed December 22, 2021
Pratt M, “What Is Distributed Ledger Technology (DLT)? – Definition from WhatIs.com” (SearchCIO2019) <https://searchcio.techtarget.com/definition/distributed-ledger>
Prentice J, “How New Technologies Help Prevent Money Laundering” (Int-comp.orgJune 18, 2019) <https://www.int-comp.org/insight/2019/june/how-new-technologies-help-prevent-money-laundering/>
Reppel O, “Digital Regulators Are a New Norm in Financial Services” (Accenture Banking BlogJune 18, 2020) <https://bankingblog.accenture.com/digital-regulators-are-a-new-norm-in-financial-services> accessed December 22, 2021
[1] Dirk Broeders and Jermy Prenio, “Innovative Technology in Financial Supervision (Suptech) -the Experience of Early Users” (2018) <https://www.bis.org/fsi/publ/insights9.pdf>.
[2] Ibid
[3] Ibid
[4] Oliver Reppel, “Digital Regulators Are a New Norm in Financial Services” (Accenture Banking BlogJune 18, 2020) <https://bankingblog.accenture.com/digital-regulators-are-a-new-norm-in-financial-services> accessed December 22, 2021.
[5] Ibid
[6] Ibid
[7] Ibid
[8] Ibid
[9] BIS Innovation Hub, “BIS Innovation Hub Work on Suptech and Regtech” [2021] www.bis.org <https://www.bis.org/about/bisih/topics/suptech_regtech.htm>.
[10] Ibid
[11] Ibid
[12] Ibid
[13] Erik Feyen and others, “BIS Papers No 117 Fintech and the Digital Transformation of Financial Services: Implications for Market Structure and Public Policy” (2021) <https://www.bis.org/publ/bppdf/bispap117.pdf>.
[14] Ibid
[15] Ibid
[16] Financial Stability Board, “The Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions Market Developments and Financial Stability Implications” (2020) <https://www.fsb.org/wp-content/uploads/P091020.pdf>.
[17] Ibid
[18] Ibid
[19] Accenture, “REGTECH the NEW WAR CRY against FINANCIAL CRIME” (2021) <https://www.accenture.com/_acnmedia/pdf-106/accenture-regtech-the-new-war-cry-against-financial-crime.pdf>.
[20] Benoît Cœuré, “Leveraging Technology to Support Supervision: Challenges and Collaborative Solutions Introductory Remarks” (BIS Innovation Hub 2020) <https://www.bis.org/speeches/sp200819.pdf> accessed December 21, 2021.
[21] Ibid
[22] Ibid
[23] Ibid
[24] Dirk Broeders and Jermy Prenio, “Innovative Technology in Financial Supervision (Suptech) -the Experience of Early Users” (2018) <https://www.bis.org/fsi/publ/insights9.pdf>.
[25] Johannes Ehrentraud and Denise Ocampo, “Policy Responses to Fintech: A Cross-Country Overview” (2020) <https://www.bis.org/fsi/publ/insights23.pdf>.
[26] Ibid
[27] Ibid
[28] Dirk Broeders and Jermy Prenio, “Innovative Technology in Financial Supervision (Suptech) -the Experience of Early Users” (2018) <https://www.bis.org/fsi/publ/insights9.pdf>.
[29] Financial Stability Board, “The Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions Market Developments and Financial Stability Implications” (2020) <https://www.fsb.org/wp-content/uploads/P091020.pdf>.
[30] Dirk Broeders and Jermy Prenio, “Innovative Technology in Financial Supervision (Suptech) -the Experience of Early Users” (2018) <https://www.bis.org/fsi/publ/insights9.pdf>.
[31] Financial Stability Board, “The Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions Market Developments and Financial Stability Implications” (2020) <https://www.fsb.org/wp-content/uploads/P091020.pdf>.
[32] Jo Barefoot, “M-RCBG Associate Working Paper Series | No. 110 Regulation Innovation: Using Digital Technology to Protect and Benefit Financial Consumers” (2019) <https://www.hks.harvard.edu/sites/default/files/centers/mrcbg/working.papers/AWP_110_final.pdf> accessed December 22, 2021.
[33] Ibid
[34] Ibid
[35] Hayley McDowell, “Banks Spent close to $100 Billion on Compliance Last Year – the TRADE” (www. the trade news.comApril 13, 2017) <https://www.thetradenews.com/banks-spent-close-to-100-billion-on-compliance-last-year/> accessed December 22, 2021.
[36] Financial Stability Board, “The Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions Market Developments and Financial Stability Implications” (2020) <https://www.fsb.org/wp-content/uploads/P091020.pdf>.
[37] Ibid
[38] Ibid
[39] Ibid
[40] Jo Barefoot, “M-RCBG Associate Working Paper Series | No. 151 Digital Technology Risks for Finance: Dangers Embedded in Fintech and Regtech” (2020) <https://www.hks.harvard.edu/sites/default/files/centers/mrcbg/files/AWP_151_final.pdf>.
[41] Ibid
[42] Ibid
[43] Ibid
[44] Ibid
[45] Ibid
[46] Ibid
[47] Vishal Marria, “Is Technology Helping or Hindering Our Fight against Financial Crime?” (ForbesJanuary 16, 2019) <https://www.forbes.com/sites/vishalmarria/2019/01/16/is-technology-helping-or-hindering-our-fight-against-financial-crime/?sh=5e03d453312e> accessed December 22, 2021.
[48] Ibid
[49] Ibid
[50] Ibid
[51] Ibid
[52] Ibid
[53] Ibid
[54] Erik Feyen and others, “BIS Papers No 117 Fintech and the Digital Transformation of Financial Services: Implications for Market Structure and Public Policy” (2021) <https://www.bis.org/publ/bppdf/bispap117.pdf>.
[55] Ibid
[56] Ibid
[57] Jon Prentice, “How New Technologies Help Prevent Money Laundering” (Int-comp.orgJune 18, 2019) <https://www.int-comp.org/insight/2019/june/how-new-technologies-help-prevent-money-laundering/>.
[58] Ibid
[59] Ibid
[60] Ibid
[61] Ibid
[62] Ibid
[63] Ibid
[64] Ibid
[65] Mary Pratt, “What Is Distributed Ledger Technology (DLT)? – Definition from WhatIs.com” (SearchCIO2019) <https://searchcio.techtarget.com/definition/distributed-ledger>.
[66] Ibid
[67] Ibid
[68] Ibid
[69] Jo Barefoot, “M-RCBG Associate Working Paper Series | No. 150 Digitizing Financial Regulation: Regtech as a Solution for Regulatory Inefficiency and Ineffectiveness” (2020) <https://www.hks.harvard.edu/sites/default/files/centers/mrcbg/files/AWP_150_final.pdf> accessed December 22, 2021.
[70] Ibid
[71] Ibid
[72] Ibid
[73] Ibid
[74] Ibid
[75] Ibid
[76] Dirk Broeders and Jermy Prenio, “Innovative Technology in Financial Supervision (Suptech) -the Experience of Early Users” (2018) <https://www.bis.org/fsi/publ/insights9.pdf>.
[77] Jo Barefoot, “M-RCBG Associate Working Paper Series | No. 150 Digitizing Financial Regulation: Regtech as a Solution for Regulatory Inefficiency and Ineffectiveness” (2020) <https://www.hks.harvard.edu/sites/default/files/centers/mrcbg/files/AWP_150_final.pdf> accessed December 22, 2021.
[78] Ibid
[79] Ibid
[80] Ibid
[81] Deloitte, “Automation of Regulatory Reporting in Banking and Securities” (Delloitte2021) <https://www2.deloitte.com/us/en/pages/regulatory/articles/automating-regulatory-reporting-banking-securities.html> accessed December 22, 2021.
[82] Ibid
[83] Ibid