Sanctions Painkiller: Series of webinars on navigating sanctions compliance

Sanctions Painkiller: Series of the webinar on navigating sanctions compliance

Amid the shifting and rapidly deteriorating geopolitical landscape, companies find themselves increasingly exposed to the risk of sanctions, operational and supervisory problems, and obligations to comply with regulations from multiple jurisdictions and organisations. Compliance measures must become more sophisticated to avoid facing penalties and reputational risks.
Over the years, the EU has imposed sanctions on a number of countries and entities, such as Iraq, Iran, North Korea, and Venezuela. In the last months, the EU and its allies have imposed a stringent sanction regime on Russia and Russian entities, amid the Ukrainian crisis.
Against this backdrop, the World Savings and Retail Banking Institute is pleased to launch a series of webinars aimed at providing critical intelligence, best practices, and key methods that institutions in the financial industry can employ the navigate the current sanction regime.
In the first webinar, speakers from Pideeco, will provide guidance and concrete examples on global sanctions and controls restrictions that will facilitate smooth overview and productive discussions.


Data Act - An open data economy should be multilateral and cross-sectoral

ESBG submitted its position to the European Commission on the proposed Data Act on 12 May. ESBG welcomed the Commission’s data strategy and its commitment to create a single market for data that will constitute a potential source of growth and innovation.

We believe that a European approach to data is essential to ensure competitiveness, avoid fragmentation of national regulations, and benefit from a scale effect. Moreover, ESBG members stressed that the horizontal regulatory approach is crucial to establish the key rules and principles for all sectors as, in our view, an open data economy should be multilateral and cross-sectoral.

The European Commission published its proposal for the Data Act in February and opened this call for feedback in March. The proposal clarifies who can use, access, and share data generated in the EU across all economic sectors, and on what terms. The Data Act aims to provide a harmonised framework for data sharing, conditions for access by public bodies, international data transfers, cloud switching, and interoperability.

The Data Act is based on the results of an open public consultation that the European Commission carried out in 2021, to which ESBG responded in September. It is the second main legislative initiative directly related to data, following the recent adoption of the Data Governance Act, which aimed to increase trust and facilitate data sharing across the EU and between sectors.

related


Overtime for Ukrainian war refugees: DSGV employees donate over 100,000 euros through extra work

Overtime for Ukrainian war refugees: DSGV employees donate over 100,000 euros through extra work

Russia’s military incursion into Ukraine has caused the largest humanitarian crisis in Europe since the Second World War with millions fleeing their country. At the same time, it has triggered various actions and reactions from the European Commission and EU regulators that heavily affect banks.
ESBG members have raised to the challenges that the crisis in Ukraine has created. On one hand, they are sharing knowledge and best practices in a coordinated way to tackle the challenges as they raise. On the other, European savings and retail banks have reaffirmed their commitment to social responsibility with direct actions and initiatives to support people in need.

Overtime for Ukrainian war refugees: DSGV employees donate over 100,000 euros through extra work

Employees of the German Savings Banks and Giro Association (DSGV) have so far collected more than €100,000 for Ukrainian war refugees. The proud sum was raised because employees donated part of their overtime. The DSGV converted the overtime donation into a corresponding cash donation.
With the overtime donation, DSGV supports various projects that benefit war refugees from Ukraine, including “Arrival Support Berlin”, “Support for Ukrainian Refugees in Moldova”, “Ukraine-Hilfe Lobetal” and the Ukraine aid of “wildtierrettung.de”. The initiatives have in common that they make it easier for people to arrive in Germany and thus make an important contribution in a difficult life situation.

MORE DETAILS

related


Stand with Ukraine: Erste family provides extensive humanitarian aid

Stand with Ukraine: Erste family provides extensive humanitarian aid

Russia’s military incursion into Ukraine has caused the largest humanitarian crisis in Europe since the Second World War with millions fleeing their country. At the same time, it has triggered various actions and reactions from the European Commission and EU regulators that heavily affect banks.
ESBG members have raised to the challenges that the crisis in Ukraine has created. On one hand, they are sharing knowledge and best practices in a coordinated way to tackle the challenges as they raise. On the other, European savings and retail banks have reaffirmed their commitment to social responsibility with direct actions and initiatives to support people in need.

Erste Bank Group (Austria, Croatia, Czech Republic, Hungary, Romania, Slovakia): Together with its subsidiary banks and ERSTE Foundation, Erste Group has been implementing a comprehensive package of humanitarian support measures for Ukrainians. For instance, since Monday 14 March 2022, the Caritas Day Centre at Erste Campus in Vienna has been welcoming Ukrainians in need from 7:00 a.m. to 7:00 p.m. – seven days a week. People on the move also have access to WiFi and quiet zones. A children’s play corner is also provided for the little ones thanks to SOS Children’s Village. In addition, all payments from Erste Group accounts to Ukraine are free of charge, with any fees incurred being refunded after the transfer to facilitate private aid payments and donations to organizations. Erste Group’s subsidiary banks offer access to free accounts for Ukrainian refugees to facilitate money transfers. Moreover, Erste Group will support its partner organizations Caritas and the International Red Cross with donations of one million euros each. In addition, the Romanian subsidiary bank BCR donated a total of 100,000 euros to Save the Children, the Red Cross, and Romanian government initiatives

MORE DETAILS

related


The German Savings Banks Association ( DSVG ): More than 100,000 accounts already opened for Ukrainian war refugees

The German Savings Banks Association ( DSVG ): More than 100,000 accounts already opened for Ukrainian war refugees

Russia’s military incursion into Ukraine has caused the largest humanitarian crisis in Europe since the Second World War with millions fleeing their country. At the same time, it has triggered various actions and reactions from the European Commission and EU regulators that heavily affect banks.
ESBG members have raised to the challenges that the crisis in Ukraine has created. On one hand, they are sharing knowledge and best practices in a coordinated way to tackle the challenges as they raise. On the other, European savings and retail banks have reaffirmed their commitment to social responsibility with direct actions and initiatives to support people in need.

DSVG (Germany): As of 27 April 2022, the German Savings Banks Association had provided Ukrainian refugees with more than 136.000 bank accounts. Refugees can easily apply online for a GiroExpress account with their ID thanks to a simplified procedure. Moreover, DSGV is providing all relevant information on bank accounts in Ukrainian and is working on extending the service to online banking, its platform for job seekers, etc. DSVG is also supporting the initiative #UnterkunftUkraine (Accommodation Ukraine) which connects volunteers with refugees looking for temporary accommodation. By the end of April, the initiative offered temporary accommodation to 24,000 people in 150 German cities, offering almost 370,000 beds, which makes #UnterkunftUkraine currently the platform with the most bed offers.

MORE DETAILS

related


CaixaBank has been leveraging its network of branches in Spain to assist asylum seekers and refugees fleeing Ukraine

CaixaBank has been leveraging its network of branches in Spain to assist asylum seekers and refugees fleeing Ukraine.

Russia’s military incursion into Ukraine has caused the largest humanitarian crisis in Europe since the Second World War with millions fleeing their country. At the same time, it has triggered various actions and reactions from the European Commission and EU regulators that heavily affect banks.
ESBG members have raised to the challenges that the crisis in Ukraine has created. On one hand, they are sharing knowledge and best practices in a coordinated way to tackle the challenges as they raise. On the other, European savings and retail banks have reaffirmed their commitment to social responsibility with direct actions and initiatives to support people in need.

CaixaBank (Spain): Since late February, CaixaBank has been leveraging its network of branches in Spain to assist asylum seekers and refugees fleeing Ukraine. Ukrainian refugees in Spain are eligible for several free services, regardless of which bank they use. Since the early stages of the emergency, CaixaBank set up interpretation and translation services to make it easy for newly arrived people from Ukraine to sign up for basic financial services. As other customers in vulnerable situations do, Ukrainians can open a Social Account at CaixaBank, which includes a checking account, a bank card, and access to online banking free of charge. Moreover, customers of Ukrainian banks are allowed to use CaixaBank’s entire network of ATMs in Spain for free.

Since early March, CaixaBank has been offering free money transfers to Ukraine and neighboring countries, where Ukrainian civilians seek refuge: Moldova, Romania, Hungary, Slovakia, and Poland.
Among the wide range of measures to facilitate aid to the Ukrainian people, CaixaBank collaborated with the CaixaBank Volunteers Association, with more than 5,000 members spread throughout Spain, to mobilize a convoy of buses to the Polish-Ukrainian border and help evacuate people wishing to request asylum in Spain. A total of 204 Ukrainians, mostly young women, and children, have already arrived in Spain thanks to this initiative, and a second convoy was scheduled for the end of April.

MORE DETAILS

related


Ukraine: ESBG members reaffirm their social responsibility

Ukraine: ESBG members reaffirm their social responsibility

Russia’s military incursion into Ukraine has caused the largest humanitarian crisis in Europe since the Second World War with millions fleeing their country. At the same time, it has triggered various actions and reactions from the European Commission and EU regulators that heavily affect banks.
ESBG members have raised to the challenges that the crisis in Ukraine has created. On one hand, they are sharing knowledge and best practices in a coordinated way to tackle the challenges as they raise. On the other, European savings and retail banks have reaffirmed their commitment to social responsibility with direct actions and initiatives to support people in need.

Associazione di Fondazioni e di Casse di Risparmio (ACRI) (Italy): On 7 March, ACRI allocated an extraordinary contribution of 2 million euros to support the activities of Non-Governmental Organizations (NGOs) assisting Ukrainian refugees fleeing their country.

MORE DETAILS

related


ESBG response to ESMA’s consultation on guidelines of MiFID II suitability requirements

On 27 April 2022, ESBG submitted its response to the European Securities and Markets Authority’s (ESMA) consultation on guidelines on certain aspects of the MiFID II suitability requirements. Published in January 2022, the paper builds on the text of the 2018 ESMA guidelines, which are now being reviewed following the adoption by the European Commission of the changes to the MiFID II Delegated Regulation to integrate sustainability factors, risk and preferences into certain organisational requirements and operating conditions for investment firms.​

In our response, we stressed that ESMA should give investment firms more flexibility in implementing the new rules. In particular, we consider that the process for collecting client information is too detailed and impractical for both the client and the investment firm, hence we proposed that it should be optional. We also noted that the two-step approach of the suitability assessment is overly restrictive and time-consuming. For these reasons, we urged that the firm be permitted to collect all information from the customer at once.

Moreover, we understand that Level 2 Regulation allows an investment firm to recommend a product that doesn’t meet the client’s sustainability preferences, if the issue is explicitly stated and explained to the client as well as documented in the suitability report. This practice is contrary to the guidelines which require the client to first adapt his or her sustainability preferences before any further discussion. Additionally, we recommended that collecting extensive client’s information should not always be necessary when, for example, an investment firm does not have any financial instruments included in its product range that would meet the client’s sustainability preferences.

Lastly, we proposed an alternative treatment of investment advice with a portfolio approach in terms of collecting client information on sustainability preferences. We believe it would be more beneficial for the client if firms were allowed to collect such information in each advice session rather than for the entire portfolio as in the case of providing portfolio management.​

related


Scale2Save brings Ugandan financial stakeholders to commit for financial inclusion

Scale2Save Campaign

Micro savings, maximum impact.

KAMPALA, 28 April 2022 – Key stakeholders of the Ugandan financial ecosystem came together during a Scale2Save knowledge sharing event, which concluded with a joint call to action with concrete steps to boost financial inclusion in the country.

Read the call to action

The signatories of this call to action, and initiative of the World Savings and Retail Banking Institute (WSBI) and its programme for financial inclusion, Scale2Save, are: the Uganda Bankers Association (UBA), Financial Sector Deepening Uganda (FSDU), The Association of Microfinance Institutions of Uganda (AMFIU), The Financial Technologies Service Providers Association (FITSPA), and the Mastercard Foundation.

“We are ready to work with all stakeholders to demonstrate the commitment of the industry, particularly in times of shocks. We are also ready to continue making contributions to the empowerment of low-income customers to seize economic opportunities, build resilience and, ultimately, have a better life”, state the signatories of the document.

This commitment was announced at the end of a 2-day Scale2Save event in Kampala entitled ‘Building resilience and economic empowerment for women and youth’ which brought together some 100 participants. Both the event and the call to action focused on the key drivers of financial inclusion such as customer-centricity, the potential of digital finance and sustainable business models.

Michael Atingi-Ego, Bank of Uganda’s Deputy Governor, described the current state of high financial exclusion of women and youth in the country during his keynote speech at the event.

“When you consider these observations about our lived reality, you start to see the imbalance that Scale2Save is attempting to address here today. This extent of financial exclusion of women and the youth tantamount to trying to balance a three-legged stool on one leg. This is unsustainable in a country that is working towards socio-economic transformation”, he said.

“I am pleased to participate in this event because the Bank of Uganda shares the objective of democratising access to and empowering the users of financial services, not least by championing the National Financial Inclusion Strategy, and through our strategic plan and operations. But like the multilegged stool, it will take the contribution of all stakeholders and partners to bring about universal financial inclusion,” added Mr Atingi-Ego.

Scale2Save is a six-year programme working six African countries including Uganda, where it partners with Centenary Bank, FINCA Uganda and BRAC Uganda Bank. Weselina Angelow is Scale2Save Programme Director. During the event, she presented some of the key lessons learned during the last years implementing financial inclusion initiatives in Uganda.

related


Developing a proportionate, fair and efficient IRRBB framework in the EU

On 4 April 2022, ESBG responded to the EBA consultation specifying technical aspects of the revised framework capturing interest rate risks for banking book (IRRBB) positions.

Our response stresses that the current framework is too complex and challenging to implement for smaller institutions with non-complex operations and limited market risk exposure. Although we need a sufficiently prudent management of interest rate risk amongst all EU/EEA banks, the framework should also consider the peculiarities of national banking models and the interest risk inherent in national markets.

As regards the definition of large decline for the purpose of the net interest income (NII) supervisory outlier test, the proposed “Option B” referring to a cost related metric seems more aligned with established internal interest rate risk management methodologies. Yet, the removal of the administrative expenses term, which generates volatility and complexity, is pivotal to favouring this option.

Considering the limited ability of the standardised approach to capture adequately the exposure of each entity to IRRBB, any obligation to use it should be conditional on the competent authority having demonstrated that it would be more relevant than the internal model approach (IMA) it would replace.

In the area of credit spread risk arising from non-trading book (CSRBB), the scope of the framework is too extensive as it includes all instruments. On the contrary, credit spreads, which are based on a market perception, should not apply to illiquid and non-market instruments whose value does not change according to these market spreads. The scope should thus be restricted to instruments that have a clear market price transparency andare easily tradable on a large and deep enough market, because only these assets are subject to the market perception. Moreover, a clear definition of the terms “market credit spread” and “market price of credit risk” is needed.

To avoid different interpretations and ensure a level playing field, it should be stated explicitly in the Guidelines, that non-marketable instruments, such as loans to customers, should be generally exempted from CRSBB as they are covered by the bank’s credit risk management framework.

Finally, the new IRRBB standardised methods for the economic value of equity (EVE) and NII seem to be very calculation intensive but, at the same time, less granular than many banks’ internal models. We therefore stress that both banks and supervisors may lose interest rate risk management insights if banks are required to apply them by their national authorities. ​

related