The first debate is finished. It’s over. Everyone in the banking and payments sectors can agree that regulatory technology, or regtech, is the future.
The unending flow of new regulations has proved the compliance industry can no longer operate effectively without regtech to take the strain.
The payments industry has been especially affected by increased regulation, with payment providers now having to conduct higher levels of due diligence to address concerns about money-laundering, fraud, money-transfer scams, and data privacy.
But regtech alone still doesn’t seem to be enough. But even with regtech, compliance departments are still struggling to cope. This has recently provoked regulators to start discussing the possibility of extending the deadlines for the implementation of MiFID II, FRTB, and GDPR.
Compliance officers across financial services will breathe a sigh of relief if the deadlines do get extended. Many I’ve spoken to are having a very tough time. And they’ve all got the same problems: legacy systems that must be updated for GDPR; the interpretation of difficult terms in new AML rules; and formulating methods to implement tricky regulations in a way that minimizes impact on our companies’ bottom line.
Extending these deadlines, though, is only tackling the symptoms, not the root cause. Compliance departments in the biggest banks and payments companies are overworked. There are too many changes coming at them from all directions, all at once. There's too many for them to cope with, even with the assistance of regtech. And there is literally no end in sight. New regulations stretch away into infinity.
The solution, I believe, is to recognise that regtech is more than simply a way to automate processes; a way to automate repeatable tasks at scale on millions, or even billions, of data points, such as monetary transfers.
In the future, I see regtech as an industry-wide platform which connects the compliance sector together; collating, analysing, and unleashing the intelligence and compliance know-how.
I believe regtech is capable of smashing through all our silos, dismantling the Chinese walls between different compliance departments on Wall Street, the City of London, and the emerging financial tech hubs. It will help us to share collective intelligence to mutualise costs and reduce risks of compliance. Ultimately, it could transform and lift up compliance, and enable it to play the absolute central role in our industry’s future.
What does this mean in practice? It means creating a shared platform that all compliance departments globally can connect to, both to share best practice and know-how, but also to access the latest emerging regtech in the form of modules that can be downloaded and installed, just like social networks allow its users to install apps.
At its most simple, this would mean compliance officers sharing best practice about implementation; at its most advanced, it might be compliance departments open sourcing new compliance algorithms to benefit the entire industry.
For example, if a payments company developed a new algorithm to effectively monitor and accurately detect suspicious cross-border transfer activity, this could be openly shared on the platform.
While this might sound crazy initially, this is not too different from the information sharing that currently takes place in the payments industry. For example, in many countries payment providers, and other financial institutions, openly share information about known fraudsters to stop billions in fraud taking place every year.
Once this platform is rolled out, tricky regulatory questions won’t have to be answered by different companies separately, which saps time and resources, rather, there will be a collective central hub that combines the experience and knowledge of all compliance officers, everywhere.
Why would companies want do this? Why would they want to share best practice and hard-won knowledge? Surely, this is all highly confidential, and sharing it with their competitors would put them at a serious competitive disadvantage?
First, it's a myth that compliance can truly be a competitive advantage. At the end of the day, as regulated institutions, we all have to comply with the same regulations. Being the first to find a loophole or solve a tricky question is unlikely to be anything more than a cause for quiet celebration.
Surely it would be much better if we all stopped fighting an unwinnable battle, saved money, and reinvested it in the value-added services that are our real competitive advantage.
Secondly, as compliance officers, our ultimate aim should be to make the global economy as safe as possible. But altruism aside, risk has a habit of turning on us later down the line, and protecting consumers from unregulated products often protects our own interests too. The best way to take control of risk will always be to work together.
Yes, software presents us with an immediate solution to the constant deadline extensions in the form of more automation. But, even in the medium term, it will not be enough.
We are missing regtech’s most significant potential: connecting compliance departments to share the latest technology and best practice. This will mutualise the cost and time we have to separately invest in compliance. But only if we let it.