Q1: John, thank you for taking the time to speak with us. Please can you tell our readers a little bit about yourself, your professional experience, and your current focus?
It is a pleasure to participate in this program and share ideas and concepts with fellow thought leaders.
I have been in the FI industry for more than 40 years and had the opportunity to work for great organizations and manage both domestic and international programs covering AML, KYC, Anti-Fraud; Investigations & Forensics and Vendor & Third Party Risk.
I recently joined the Neo Group Inc. team where we provide a full range of Sourcing Advisory support to buy side companies covering Global Talent, Automation/RPA, Analytics, Process Optimization, Governance and Risk Monitoring.
Q2: You will be delivering a presentation based around advancing internal/intragroup agreements to the same level of rigor as external third party partnerships. Why is this necessary for banks to do, and why has this become an important talking point?
In addition to meeting the requirements of our regulatory partners in the areas of Living Wills and cross Legal Entity sourcing, it is critical to ensure our risk governance covers the entire, end to end sourcing chain. It is not uncommon for a single external Third Party relationship to involve downstream support to numerous bank units and businesses in multiple jurisdictions. All of which may be required to meet local “outsourcing” guidelines and protocols.
Q3: What challenges should banks be aware of when advancing internal/intragroup agreements?
While there are many control requirements to be addressed, the first step is a clear understanding of the data sets involved and confirmation from both the sending and receiving unit’s Compliance, Legal and Data Privacy managers that all laws and regulations have been reviewed and the sourcing is permissible.
Q4: Why is internal transfer pricing and ensuring fair pricing for services a key talking point?
In the US as well as other jurisdictions regulators require the banks to ensure that the pricing structure does not improperly benefit/penalize one legal entity over another.