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Looking back after 10 years of SEPA
| 26-02-2018 | Paul Stheeman |
Last month we saw the anniversary of several historical moments. 1000 years ago, in January 1018 the Peace of Bautzen ended the German-Polish War. More recently, in January 1998, American President Bill Clinton surprised the world by denying in a press conference that he had sexual relations with Monica Lewinsky. More importantly for Treasurers and the citizens of Europe January 2018 marks the tenth anniversary of the establishment of SEPA, the Single European Payments Area.
In Europe we have become used to SEPA. Initially we all groaned at the idea of having 22-digit long bank accounts numbers called the IBAN, nicknamed as “IBAN the Terrible”. But the introduction of SEPA in January 2008 has brought a number of benefits to over 520 million citizens in Europe. Not only are the 19 Eurozone countries members of SEPA. All other EU countries participate as well as countries such as Norway or Switzerland.
The main benefit is that we now have one payment zone. Previously, making a transfer from Italy to the Netherlands was a cross-border payment. This meant that a whole week could pass between the time when the payer initiated the transfer in Italy and the recipient actually received the funds on his Dutch bank account. In addition, banks in both countries would charge considerable fees for making the transfer. Payment is now done within 24 hours and banks should not charge more than for a domestic payment.
SEPA not only covers transfers. Direct debits and debit cards also are handled in a similar manner through SEPA. And a new instant payment scheme is currently being rolled out, allowing payments to be completed within seconds on a 24/7/365 basis.
SEPA is also strongly regulated. The European Commission established the legal foundation through the Payment Services Directive or PSD. Payment products are overseen as are technical standards.
In the last ten years SEPA has established itself as being the platform for payments in Europe. Due to its wide acceptance and success in its first decade it is likely to accompany us for many years ahead as new payment methods are developed in the digitalised world.
Paul Stheeman
Owner of STS – Stheeman Treasury Solutions GmbH
Internal Fraud – or how not to cheat yourself
| 22-02-2018 | Lionel Pavey |
Fraud is normally caused by false representation, failure to disclose information and abuse of power and position. As fraud is performed by people and their actions, a first step to prevent fraud would be to look at the current working environment within a company. If a company is putting extra stress on employees – bigger targets, loss of overtime payments, reductions in secondary benefits, no pay rises nor promotions etc. whilst the directors receive bonuses– this can lead to employees becoming aggrieved and seeking retribution. Furthermore, employing more temporary staff and external contractors, can distance the remaining employees and challenge their allegiance and loyalty.
Internal procedures
One of the least sexy components within a company is internal procedures. They need to be drafted, amended, agreed, published, implemented and reviewed on a rolling basis. Very few people enjoy writing these manuals, but they are essential to ensure that everyone is aware of the correct procedures that have to be followed to perform any tasks. Often there is talk of a “four eyes principle”. Personally, I have always believed in a “six eyes principle” as it requires more independent control and makes fraud less easy to perform. Most of the procedures are, of course, built around common sense. Duties should be segregated – different departments have different roles to perform in ensuring the complete procedure is followed throughout the company. Even within a single department, attention should be paid to segregating duties.
An example would be the administrative function relating to a purchase. There are 4 distinct stages – procurement, arrival, warehousing and dispatch/shipment. If one member of staff was responsible for the relevant data input for all 4 stages, there is an increased risk that fraud could take place. This is not to say that work should be segregated that one employee only ever does one function – this could also lead to fraud either through disenchantment or over familiarity of the systems and procedures used at one specific point in the production chain.
External procedures
Certain departments within a company have contact with external sources – suppliers, clients, financial institutions. Anyone who has contact with an external counterparty can be swayed by opportunity if the controls are not in place. In respect of purchasers – what contact do they have with suppliers outside the office? Are they entertained – restaurants, sports events etc? How often do they have contact? In respect of sales – are they responsible for determining the sales price? How often do they see clients and spend money on them? The same also applies to treasurers, cash managers, risk managers etc.
The necessary checks and balances need to be put into place. A record of all contact with external parties needs to be kept, updated, verified and stored. Temptation can be caused by personal hardship, flattery or grievance at how the person is perceived to being treated by the company.
Standing up to the boss
As stated, a healthy company should have procedures and statutes in place. These need to be adhered to at all times – there can be no exceptions. However, a mechanism for escalation is often missing. Example – someone sends in an expense claim approved by their manager. The treasurer or controller might question the veracity of a particular entry. A proper mechanism to escalate the discrepancy needs to be firmly established. That a manager has signed off on the expense claim does not mean it is correct.
Even directors have to make sure that their claims are signed off by other members of staff. Being at the top does not mean that the procedures do not apply. Requests for a priority payment outside of the agreed procedure should always be questioned. If everyone has agreed to the standard procedures, then there can be no justification to make a payment outside of the normal procedure, just because it has been deemed a priority. If truly deemed necessary, then authorisation must be given not only by management and directors, but also by the legal department. If this occurs, then the existing procedure needs to be examined as to why the incident occurred and where the procedure broke down. This all has to be detailed in writing – fraud can happen at the highest level as well as low down with an organisation.
Static data
Every contact both inside and outside of the company should be recognised and recorded in a data system. Static data refers to all relevant data concerning an entity – full name, registered address, bank details, contact details etc. This data should be fed into all other systems, but data input should be restricted to a small number of employees. These employees should not have access to any of the systems that are used to input data relating to daily operations.
Another key area is in the cash management side – book keeping can be complex and differences not noted until the yearly audit. However, cash movements contain plentiful details – name of beneficiary, account numbers etc. This can be reconciled against the prevailing static data – are the bank account numbers the same?
Fraud can never be eradicated, but by being open, allowing questions to be asked, even performing unexpected checks on the system and its integrity, and creating an atmosphere where staff know that they can question without fear of reprisal, then at least everyone will know that the company is alert and vigilant.
That knowledge and awareness will make a potential fraud think twice.
High Road or High Horse?
| 21-02-2018 | Pieter de Kiewit |
Now I am not known for being politically active or interested. Many of my clients are corporates that are in the line of fire following the whole Panama Paper affair. So understanding what is happening would make sense, perhaps I could even form an opinion. So far, this is what I see and think:
• Newspapers created news by publishing what has been known for a long time. As far as I can oversee there were no convictions in The Netherlands based upon the Panama Papers;
• Poor countries are put in off side position when it comes to receiving taxes;
• Politicians created the rules and now shout from their high horse that corporates, following their rules, lack proper business ethics;
• Large corporates are able to hire the best tax lawyers and enjoy the largest tax cuts;
• Newspapers pick the corporates with the most prominent brands as an example and do not tell the story of both sides.
This equation has (too) many variables. I think Joris Luyendijk’s remarks about being immoral or amoral (https://www.theguardian.com/sustainable-business/2016/jan/18/big-banks-problem-ethics-morality-davos) are very relevant. The difference between “I follow the rules” and “I follow the rules and think about if they are right and enough”.
Given the fact that the revenue of the large corporates is bigger than the GDP of many countries, we cannot solve the problem locally. We cannot decide for other countries but we can decide for our own. Do we want to be on our high horse and economically weak? Would that be taking the high road? I am afraid I do not oversee the full picture. If I do, am I willing to accept the consequences as a consumer, entrepreneur and employer?
Would you?
Pieter
Pieter de Kiewit
[email protected] / +31 6 1111 9783
Pieter de Kiewit
Owner Treasurer Search