Tag Archive for: Compliance

GDPR: From compliance headache to business opportunity

|24-07-2018 | Reuters | treasuryXL |

The Information Commissioner’s Office has described the new GDPR laws as “the biggest change to data protection law for a generation”. Businesses will face a maximum fine of up to £17 million or 4% of global turnover, if they breach the EU rules. These are critical, but turbulent times for businesses across Europe. However, if organisations of all sizes play their cards right, GDPR can be transformed from a compliance nightmare, into a business advantage.

Competitive advantage

“General Data Protection Regulation is generally seen in a fairly negative light, particularly by organisations. But I think there is a huge opportunity to differentiate services based on trust. The consumer gains from interaction with any institution,” according to Managing Director and Data Protection Officer at Barclays, Jon Rees. He adds: “Our recent research has shown that the number one concern – across many different demographics and usages – is security of customer information, and how it’s being used. There’s a competitive advantage to be had by applying GDPR in a positive way.”

Consistency by design

As a ‘complex corporate’ itself, Barclays has seen another major benefit of GDPR, and that’s the obligatory enforcement of good practice and consistency by design across organisations, in terms of the harmonising of data systems. While it’s still early days, transparency is fast-becoming the buzzword of GDPR’s inaugural year.

Consumer confusion

There are, predictably, some areas of confusion that are emerging, especially for consumers – in part accelerated by miscommunication. People are confused about what their individual rights are when it comes to personal data and consent, and right to deletion. Some are interpreting consent as: ‘unless I’ve given a firm my approval, it has no right to use my data’. While this is not correct, the lack of understanding is unsurprising, given the complexities of GDPR and it being in its infancy. However, this is where businesses can once again shine. Those that are helpful, and offer clear communication with their consumers on GDPR, will come out on top as trustworthy brands that always put the customer first. A more consumer-centric approach is, after all, at the heart of GDPR.

Visit the website of Reuters to read the full article.

 

[button url=”https://www.treasuryxl.com/contact/” text=”Contact us” size=”small” type=”primary” icon=”” external=”1″]

[separator type=”” size=”” icon=””]

Static Data – unsexy, but imperative to workflows

| 23-04-2018 | treasuryXL |

We live in the world of Big Data – we are told that there is so much potential that can be unleashed by embracing Big Data. This can lead to business efficiency, increased revenue, reduced expenditure, earlier identification of fraud etc. But for all this to reach fruition, we need to rely on the most basic building block – Static Data. Many companies have grand ideas of how to maximise revenue with data streams, yet fail to grasp the essential need for good, sound, structured Static Data.

Definition

This is data that remains constant (mostly) during the lifetime of its use; once input and recorded it becomes static and is used as reference data. The most logical example would be the data on relationships – when a company starts trading with a new supplier, a new record needs to be added to the bookkeeping system.

Types of data include:

  • Legal name of counterparty
  • Short name
  • Legal address
  • Telephone number
  • Fax number
  • Email
  • Contact persons
  • IBAN
  • BIC Code
  • KvK number
  • BTW number

Once the Static Data has been input it should only be changed by authorized staff. Dynamic data – the lifeblood of Big Data – can later be input (trades, invoice numbers, delivery dates, amounts etc.), but it needs good Static Data to make the data consistent. The complete data set for a counterparty must always be unique – there can not be 2 entities with the same set of data.

The structure of the data is also important – it could quite easily be the case that a company has one large client with the same bank details, but relationships with 5 different divisions. It is therefore essential that the correct protocols are in place for consistent data – whilst the legal name will be the same the importance of the short name becomes evident.

When it goes wrong

Inter company communication does not always involve use of a bookkeeping system. If staff start referring to a counterparty by another name than is in the system or use a name that is in the system but not the name they mean, problems can occur. Incorrect bookings arise which can lead to incorrect exposure levels or limits being breached. It can also be that a legal entity in a different country is referenced as they have offices in more than 1 country and issues such as VAT (BTW) can suddenly appear.

The need for secure Static Data is very high – the consequences of errors should never be underestimated. Data entry should be undertaken by people who do not enter any other data into the systems – in other words it should not be undertaken by the same staff that work in debtor and creditor administration.

Furthermore, a clearly defined protocol needs to be implemented to determine when and how Static Data can be changed.

In a little more than 1 month from now, GDPR comes into effect. The urgency to understand Static Data and to appreciate its significant contribution to daily operations has never been greater.

If you have any questions, please feel free to contact us.

[button url=”https://www.treasuryxl.com/contact/” text=”Contact us” size=”small” type=”primary” icon=”” external=”1″]

[separator type=”” size=”” icon=””]

Smart contracts – oxymoron or the future for business?

| 16-03-2018 | treasuryXL |

On Tuesday 13th March 2018, RTL Z – a television channel – broadcast a “Cryptoshow” to explain how the Blockchain works and what it could mean for the future. They attempted to make the technology and information as simple as possible to show what uses the Blockchain could have in the world for consumers and businesses. One of the main areas of interest relates to Smart contracts. What are they? What are the advantages and disadvantages? What changes can they bring?

Definition

Wikipedia defines a Smart contract as “a computer protocol intended to digitally facilitate, verify, or enforce the negotiation or performance of a contract. Smart contracts allow the performance of credible transactions without third parties. These transactions are trackable and irreversible”.

These contracts facilitate the transfer of goods, services, property, money – in fact anything of value – in a manner that is transparent and direct. It removes the role of an intermediary.

How they work

  • You agree to enter into a transaction
    You draw up an agreement electronically
    The agreement is encrypted and placed on a secured shared ledger accessible to the counterparty
    As this is the Blockchain, the data is backed up at various other locations
    Both parties perform as per the agreement
    Costs are reduced by the absence of intermediaries
    As both parties have agreed to the contract they are faster and less expensive to administer
    Being electronic there is less possibility of errors occurring due to manual input

Advantages

  • Both counterparties receive an identical agreement
    You decide who can access and amend documentation
    Rules that have been agreed upon define how changes can be made
    Any agreed change in one document is automatically made to all relevant documents
    Encryption and the methodology of the Blockchain ensures that transactions cannot be altered after being agreed and the block validated

Disadvantages

  • Are they enforceable by law
    No action written in a contract can be against the law of the land
    Contracts still have to be written – electronically. This entails human involvement that could lead to errors
    Considerable knowledge of computer coding is required
    Lawyers still need to be involved in the formation of the contracts
    Costs – employing these specialists will come at a steep price

What further uses can the Blockchain provide

Digital identity – it will be possible to identify an agreed counterparty and all their static data can be stored
Proof of provenance – especially for ethical businesses, it will be possible to issue certificates proving the source of goods
Communication within the supply chain – discrepancies will show up and can be proactively addressed
Payments – removing financial intermediaries implies quicker payments and reduced costs
Ownership – Smart contracts enforced by law make it possible to register the legal owners of goods and property
Loyalty programmes – with all the details present from all transactions, it is possible to initiate programmes to reward clients/customers

The greatest savings will be seen in processing – both in time and costs. Some reports suggest savings of up to 40% can be established, together with a real-time overview of positions. However, the whole system relies on one major factor – trust. Where we previously met people, negotiated, agreed etc., now we will do more of that online. Furthermore, implementation of a Blockchain strategy will require a company to complete revaluate their current way of working, leading to considerable planning and strategic positioning.

The proposed future looks exciting – it is now up to industry to determine the road on which they wish to travel.

Corporate governance – it is all about the rules

| 08-03-2018 | treasuryXL |

Corporate governance is the rules and processes by which a company is controlled and directed. It is a balancing mechanism between different stakeholders – directors, shareholders, management, government, external financiers etc. The treasury function performs highly skilled and complex tasks to ensure continued and harmonious execution of all cash related functions. At the same time, there is much interaction with both internal and external stakeholders. The corporate governance within the treasury function should always be performed in accordance with predetermined and approved metrics as laid out in Treasury statutes. This means undertaking operations that are consistent with the governance within the corporation.

Corporate governance helps to define the strategies of a company, and highlight how these strategies will be implemented throughout the policies, procedures and working processes. Normally, Treasury statutes are drawn up by treasury and management – detailing the accepted methodology to perform the approved tasks – whilst responsibility and approval is granted by the directors. Once agreed upon, the statutes have to be observed by staff carrying out their duties and responsibilities.

As the treasury function is highly complex – both in financial products as well as regulatory frameworks – both directors and management need to fully comprehend the functionality as well as the implications of different financial products and services. The onus lies on the treasury department to ensure that other stakeholders not only have enough knowledge about the products, but also awareness and understanding of the relevant risks. This is vital to ensure that the right decisions are made at the highest strategic level.

Directors and management need to understand:

  • Financial risks undertaken whilst running the business on a day-to-day basis
    Operational controls to protect the business from fraud
    Risks inherent in approved financial instruments
    Strategies used to identify and mitigate financial risk
    How risk is measured and reported
    Potential exposure as a result of the agreed policy
    Acceptance that not all risks can be qualified and quantified
    The influence of external factors – market risk, counterparty risk, interest rate risk etc.

Proactive role of the Treasury

  • Accurate valuation of financial products used – if you cannot value it, you should not be using it
    Quick recording of all transactions
    Ensuring with controllers that all financial products are correctly input for accounting purposes
    Implementation and management of agreed Treasury policies
    Determining if bank covenants are being maintained
    Ensure compliance with all external regulatory frameworks
    Collaborating with auditors – both internal and external

Policy is influenced by strategy and objectives. The role of Treasury is to help to fulfil those objectives. Treasury has a dual function – it both mitigates risk as well as being the source of risk. Treasury enters into financial transactions on behalf of the business in order to mitigate risks; however, something like an unauthorised trade could subject the business to financial loss.

It is essential that directors and management understand both the risks that treasury manage, together with the potential risks that those transactions can create.

MiFiD II – 10 days old: Status Report

| 16-01-2018 | Lionel Pavey |


MiFiD II is a regulation leading to reform in the European financial industry. This is an update to the original MiFiD regulation which started in 2007. It is expected to offer greater protection to investors and to increase transparency within the markets. There is a strong determination to move trading from “Over the Counter” such as voice activated markets, to more established electronic venues as these are easier to audit and monitor.

 

What are the aims of MiFiD II

  • Greater transparency and efficiency in markets
  • Moving from OTC trading to regulated trading areas
  • To restore confidence lost by investors after the financial crisis

What markets are affected

  • Equities
  • Commodities
  • Fixed Income
  • Foreign Exchange
  • Futures

Who is affected

  • Everyone who is a participant in the market

How will it work

  • Caps on the volume that can be traded in dark pools
  • Pricing transparency for OTC markets
  • Division between payments for trading and payments for research
  • Increased standards for investment products

What has happened since 3rd January 2018

Some major exchanges – Eurex, London Metal Exchange, ICE – have received reprieves from implementation and do not have to fully comply with open access rules for the next 30 months. This is despite legislation that took more than 5 years and was delayed for 1 year. This also means that certain investors will choose a deliberate route to market for their transactions that do not need to be fully reported on for the next 30 months.

ESMA (European Securities and Markets Authority) announced on 9th January 2018 that there will be a delay in implementing the cap on dark pool trading volumes until at least March 2018. These dark pools are favoured by investors and traders who wish to trade a significant amount of stock without the rest of the market knowing or the price moving.

Markets that have traditionally worked on voice activated trading – fixed income and interest rate derivatives – are still going strong. However, there is a threat to their existence if more trades are done on recognized exchanges and/or platforms.

What about research

As the cost of research has now been split from trading, it will be very clear what an investor is having to pay. Furthermore, analysts will be more inclined to only produce analysis on the larger “Blue chip” companies – both for equity and fixed income. There is a fear that smaller companies will now fall away from the spotlight and little or no research will be produced and published. Consequently, investors might become averse to taking a position in a small company where there is no research available. There is a threat that what independent research is produced will be biased as the cost for the research has to be earned back. There are rumours that maybe the exchanges will pay for research – this could be paid out of listing fees.

So, to conclude, MiFiD II is alive and running – but they are some serious disappointments compared to how it was envisaged. Perhaps such all encompassing legislation should be reduced to bite sized chunks and drip fed into the market. Any legislation that is late in being implemented and extends to more than 17 million words is, perhaps, not what the market needs and/or wants all in one go.

Lionel Pavey

 

 

Lionel Pavey

Cash Management and Treasury Specialist

 

Intercompany financing – complying with procedures

| 18-12-2017 | treasuryXL |

Many businesses (not just multinationals) finance the operations of their subsidiaries/affiliates via intercompany loans. During the financial crisis external funding became more difficult to obtain, and more businesses attempted to finance their operations internally. Whilst this can be a good procedure, consideration must be given to the fact that the loans must still be proper loans, compliant with normal market practices. Below we attempt to explain the relevant procedure.

Arm’s length principle

All terms and conditions of the intercompany loan – with special consideration for the interest rate – must be consistent with independent external loan funding. A business can not adopt a more generous approach to funding its subsidiaries than could be obtained externally. The pricing of the loan must reflect the perceived credit risk of the entity that is seeking funding.

Documentation

Just as with external financing, legal documentation needs to be drawn up and signed that clearly shows the terms and conditions of the loan. Standard covenants should be included together with a schedule showing repayment of principal and interest. If a subsidiary is granted an embedded option (early repayment without a penalty) then this must be clearly noted. Whilst the documentation does not have to be as large as that used by banks, it should always contain all relevant clauses, and both parties must adhere to the signed loan agreement. Included within the documentation should be a detailed explanation as to how the price and spread was determined, along with external data proof.

Credit modelling

As most subsidiaries are small and have no independent credit rating, an approach must be taken to attempt to define their creditworthiness. Standard metrics can be used to ascertain an internal rating. Just with a normal external loan, attention should be paid to the ability to repay. Whilst tax authorities may question the integrity of the credit modelling matrix, this can at least be negotiated if a dispute arises. If no matrix is available, then problems can occur.

Pricing

As previously stated, an internal loan should replicate the general conditions of an external loan. That means that when trying to determine the interest rate, full attention should be given to the funding costs of the main company. They need to determine what price they would pay externally to fund the loan and then apply a premium to the subsidiary. Traditionally rates can be fixed or floating with a premium.

Corporate Governance

Internal loans should always be monitored. They should not be a quick substitute for proper due diligence. Problems can easily arise if tax authorities reached the conclusion that the loan is being extended to a loss-making entity that would not receive funding externally.

Debt Compliance – can you make the grade?

| 01-12-2017 | Paul Stheeman |

Debt ComplianceWe welcome a new expert – Paul Stheeman, who immediately brings us an interesting topic that has not been covered in much detail up to now. It goes to show that there are many facets in the role of treasurer and we can constantly find new subjects that have not been approached. Thank you, Paul.

Depending on the financing method chosen, your company is likely to have debt or some kind of financial obligations to third parties. This can be in the form of loans, bilateral or syndicated, or in the form of a bond issue. In each case, the underlying agreement has to be well-documented and could be very extensive with several hundred pages of legal language which, for a non-lawyer, may be very difficult to understand.

In that documentation there will be clauses stating what the debtor is allowed and not allowed to do. Another important part of the agreement will be around financial covenants. These are usually ratios which the debtor has to regularly fulfil. It is commonly the responsibility of the Treasurer to ensure that the terms of the agreements are adhered to and to report the status of the covenants to the lenders and investors. To be able to do this the Treasurer will have to work closely with the company’s lawyers, the accountants and the Controller. He furthermore has to “educate” key internal stakeholders in the requirements, so that they also are aware of any hurdles which may prohibit them in carrying out their day-to-day business. This whole process is commonly known as debt compliance.

A loan agreement will typically have between one and five financial covenants which need to be tested and reported to the lenders on a quarterly or semi-annual basis. One of many examples of financial covenants is a coverage covenant, which requires the debtor to maintain a minimum level of earnings or cash flow relative to certain expenses, e.g. interest or debt service. Typically, such numbers are prepared in the accounting department, but the Treasurer will have to ensure that these figures are prepared timely and are within the thresholds allowed in the financing agreements. If these criteria are not met, then the debtor will be in breach of the covenant(s) and technically will be in default.

Default can also arise when so-called prohibited transactions are entered into or “basket” limits are overdrawn. In many agreements the debtor is not allowed to enter into any other financial obligation. This may in practice prohibit the debtor in carrying out his normal course of business. For example, he may be required to issue a performance guarantee. This would initially not be allowed under the agreement. Lenders therefore establish baskets with a threshold amount up to which the debtor may have a bank issue a performance guarantee. Again here, it will be the Treasurer’s responsibility to ensure that all such transactions fall within allowed business or baskets.

Being in default due to a breach of a covenant or a basket could mean that the outstanding debt becomes immediately repayable in full. This is usually neither in the interest of the debtor or the lender, so that the lender can apply for a waiver. It will depend on the seriousness of the breach, but these waivers are often agreed to by the lenders. However, there will be a fee which the lender will have to pay for the waiver and this can be quite substantial.

To summarize, debt compliance is a very important part of a Treasurer’s role as the consequences of non-compliance can at best weaken the company’s position towards its lenders and at worst be disastrous as lenders call on outstanding debt to be repaid immediately.

 

Paul Stheeman

Owner of STS – Stheeman Treasury Solutions GmbH

 

GDPR and its effect on your business

| 24-10-2017 | treasuryXL |

As if the finance industry is not already facing enough challenges swimming though the sea of regulatory acronyms – BASEL iii, EMIR, MIFID ii, SOX, KYC etc. – a new directive is due to come into force on the 25th May 2018, namely GDPR.

GDPR (General Data Protection Regulation) is an EU directive concerning personal data of EU residents that is held by companies. It is intended to give EU residents more control over their personal data by dictating how that data is held by companies. Any data that could be used to determine the identity of an individual must comply with GDPR. Furthermore the definition of personal data has been expanded from the usual name and address information to including such things as IP addresses, cookie data, photographs, minutes from a meeting where people are named etc.

The law states that any company that stores or processes personal data about EU citizens within EU states must comply with GDPR. Main criteria for compliance include:

  • A presence in any EU country
  • No presence in the EU, but processes personal data of EU residents
  • More than 250 employees

At first glance most small businesses would be exempt but, there is a provision in Article 30 that shows this is not completely true. The following explanation has been externally sourced:

The only time the articles allow concessions for organisations with fewer than 250 employees is in Article 30 – Records of processing activities. Most organisations will have to maintain a record of processing activities that contains the name and contact details of the controller, the reason for the processing, a description of the type of personal data or category being processed, how long the data will be kept before it will be deleted, and some other requirements.

 Point 5 of Article 30 states that the requirements will not apply to an enterprise or an organisation employing fewer than 250 persons unless the processing it carries out is likely to result in a risk to the rights and freedoms of data subjects, the processing is not occasional, or the processing includes special categories. Therefore, a company that processes data on a regular basis or processes special category content such as racial, political or genetic (and others listed in Article 9) material, even if quite small, will not be excluded from this requirement.

Source: https://www.fsb.org.uk/first-voice/act-now-to-comply-with-new-gdpr-rules

Even sole traders hold data, not just of other companies (trading partners) but also of individuals. As a sole trader it is possible to think that the law does not apply to them, but a more prudent approach would be to review all data held. Data can be held in a myriad of locations:

  • Hard drives
  • USB sticks
  • Dropbox
  • Cloud
  • Evernote
  • Whats App

Having discovered all the data the you hold on others, it is then necessary to design a method to protect that data. Just applying a password protection to your computer is not enough – additional security can be provided by encrypting data.

The rights of the individual are clearly defined by GDPR – these include:

  • The right to be informed
  • The right to restrict processing
  • The right to refuse to become a data subject
  • The right to be forgotten
  • Data portability

The penalties for companies failing to comply with GDPR and failure to disclose data breaches include fines equivalent to 4% of global annual turnover for the preceding financial year or EUR 20 million, whichever is the greater.

What can you do to prepare for GDPR?            

All companies that handle client data have a duty to protect that data. That means you need to locate, identify, control and delete data if so requested by the individual. Furthermore, individuals have the right to know how and why companies are using their personal data and if that data is shared with any third parties.

This means starting with a thorough examination to find and identify all third party data that you hold and why. This data then needs to be examined and protected. Data should be held at 1 primary source – ensure data is not duplicated. Clients need to be informed of the data you hold on them.

Whilst this is a considerable challenge, there is a potential advantage to be gained by clients knowing that you are complying which could lead to a rise in the trust they have in you and your organization.

Remember – you only have about 150 working days left to implement!!

From Fintech to Regtech… from potentially disruptive to leaner compliance opportunities

| 31-5-2017 | François de Witte |

On 18/5/2017, I attended a seminar covering the topic “From Fintech to Regtech… from potentially disruptive to leaner compliance opportunities” organized by The Finance Club of Brussels, the Free University of Brussels (ULB), the Solvay Finance Society and Thomson Reuters.

Introduction

Fintech describes a wide range of innovation in financial technology, going from payment systems to lending and trading platforms.
Fintechs are seen in many cases as potential disruptors of the traditional intermediation of heavily regulated banks and other financial institutions See also my articles on PSD2 further down.
However Fintechs can also be enablers, helping banks and financial institutions to streamline their regulatory reporting and compliance, or help the disruptors in coping more easily with compliance in the future.

Setting the scene

Fintechs are playing an increasing role. The investments in Fintechs exceeded EUR 25 billion in 2016, and they bring a real digital revolution. Fintechs are perceived to foster the Digital Revolution, but equally to increase the digital divide in our society between the skilled and/or wealthy and those who are not.

Regulatory compliance is time-consuming and expensive for both financial institutions and regulators. The volume of information that parties must monitor and evaluate is enormous. The rules are often complex and difficult to understand and apply. There is a lot of data to be analyzed. Much of the process remains highly labor-intensive, or still depends heavily on manual inputs.

The Regtechs can be considered as an outgrowth of Fintec. Regtech use digital technologies— including big data analytics, cloud computing, robotics, behavioral analysis, blockchain technology and machine learning to facilitate regulatory compliance. Amongst  other things, Regtech applications automate risk management and compliance processes, enable companies to stay aware of regulatory changes around the world, facilitate regulatory reporting and support strategic planning.

In recent years banks have seen opportunities to ask Fintechs to solve their large regulation and compliance issues. They can change the paradigm of banks from heavy IT releases to agile sprints, from integration to standardizing protocols, from static functions to workflows.

Hence financial institutions are more willing to consider using Fintechs for getting more efficiency. During the seminar, somebody of the panel mentioned: “Collaboration is the best innovation”. Banks can also help Fintechs thanks to their experience in managing large databases, managing risks and providing the required critical mass.

We have seen some applications recently in areas such as the KYC (Know Your Customer) domain.

Regtech – some other considerations

However, as mentioned during the seminar by Antonio Garcia Del Riego, Head of EU Corporate Affairs at Banco Santander, in Europe there remain obstacles in using Fintechs. The Bank Regulators in Europe expect the banks to deduct the goodwill from the core capital of the banks. This implies that software investments cannot be capitalized and need to be written off immediately in the P&L. A second challenge is the ability to attract digital talent, given the fact that the regulators limit the way in which the remuneration can be paid, whilst startups can be very creative here.
For the regulators, there also remain challenges. Once banks will have automated their reporting, the regulators will have to follow. They also will have to attract digital talent, to treat all these data in an automated way. If they do not succeed in this, they might challenge the use of Regtechs, and this is not what we want.

Regtechs can potentially offer similar benefits to regulators as they do to financial institutions. We recently observed that some (quite few) Regtech providers have emerged to serve the significant needs of regulators. There have seen recently some examples in Fintechs bringing behavioral models to the regulators, or new cognitive technology or the use of Blockchain technology (smart contracts), to trigger automatic alerts for the regulators when the banks exceed some thresholds.

Some regulators are taking initiatives to foster innovation. In 2016, the FCA (US) created its “regulatory sandbox,” a space where financial services companies are encouraged to test new products without regulatory consequences. Recently the Australian Securities and Investment Commission also created its regulatory sandbox, suggested to establish a new regtech liaison group, comprising industry, technology firms, academics, consultancies, regulators and consumer bodies, and announced that it would host a Regtech hackathon later in 2017.

Other countries have also taken steps to support Fintech and Regtech innovation. The Monetary Authority of Singapore is in the process of developing a regulatory sandbox. We might expect other regulators to also take similar initiatives.

Conclusion

Thanks to their digital technology, Regtechs enable banks and other financial institutions to reduce the burden of compliance. However some steps need to be taken to create a level playing field and some topics will have to be clarified.
One can ask oneself the question how far these innovations can become game changers, awakenings for the banks, or even force them to more transparency and predictability towards regulators.

 

François de Witte – Founder & Senior Consultant at FDW Consult

[button url=”https://www.treasuryxl.com/community/experts/francois-de-witte/” text=”View expert profile” size=”small” type=”primary” icon=”” external=”1″]

[separator type=”” size=”” icon=””]

 

More articles on this subject:

PSD 2: A lot of opportunities but also big challenges (Part I)

PSD 2 : The implementation of PSD 2: A lot of opportunities but also big challenges (Part II)

[separator type=”” size=”” icon=””]