The sphere of control - Financial Services · 2019-11-28 · The sphere of control. Contents INTRODUCTION Evolving ecosystems, evolving threats 3 SECTION 1 Financial crime: a disaggregated

Accenture 2019 Global Risk Management Study Banking ReportDiscover how banking leaders are taking a holistic view of the risk landscape, prioritizing what they do know and preparing for what they don’t.

The sphere of control

ContentsINTRODUCTION

Evolving ecosystems, evolving threats

3SECTION 1

Financial crime: a disaggregated ecosystem exposes new vulnerabilities

7

SECTION 2

Credit risk: a new way to tackle an old foe

12SECTION 3

AI tools ease compliance with new regulation

14

SECTION 4

Combatting cyber threats in a digital, open banking era

17SECTION 5

Don’t overlook LIBOR retirement

21SECTION 6

How banks can manage today’s major threats

25CONCLUSION

Define your sphere of control28

Evolving ecosystems, evolving threatsBanking risk teams need a fresh approach to manage the threats unleashed by emerging technology, open banking, and relentless competition.

INTRODUCTION

Accenture 2019 Global Risk Management Study Banking 3

Welcome to Accenture’s 2019 Global Risk Management Study report on banking.

This year we explore how banks are responding to emerging risks, particularly those relating to financial crime, credit risk, changing regulation, cyber threats and LIBOR retirement.

This report presents the findings from our 2019 Global Risk Management Study, which uncovers how 683 surveyed risk executives across the entire financial services industry, including those working for banks, insurance and capital markets businesses, are adapting to the ever-increasing pace and volume of change outside the four walls of the organization.

What did we find in the survey? Let’s quickly recap before delving deeper into the banking findings.

For a start, risk managers across financial services acknowledge that complex, interconnected new risks are emerging at a more rapid pace than ever before. Nearly six in ten say that disruptive technology risk has greater impact on their business today than it did two years ago.

A major cause of their concern relates to the growing adoption of new technologies across the organization. Of course, these technologies hold immense potential to unleash growth and drive efficiencies, but risk functions worry about the potential for unforeseen consequences, which they are currently not capable of identifying or assessing.


Introduction Evolving ecosystems, evolving threats

Faced with an increasingly complex, but data-rich risk environment, risk functions should invest in smart technologies such as artificial intelligence (AI) and natural language processing (NLP) that have immense potential to improve effectiveness and efficiency. Indeed, survey respondents that have deployed machine learning feel much more confident that they have prepared their business for volatile future scenarios.

But while the benefits are significant, risk functions’ use of the most sophisticated technologies is currently limited. Our study findings indicate that the risk function is aware of the need to embrace these new tools, but is simply slow in making effective use of these to date.

Technology aside, an effective risk function is one that is armed with the data it needs to anticipate, assess, and ultimately mitigate emerging threats.

But today, many are not. For example, 57 percent of our study respondents expect to use marketing data to support their risk management activity in two years’ time, but only 39 percent do so today.

Getting access to relevant data is one thing, but maintaining the quality and knowing how to analyze it effectively to generate useful insights remains a significant challenge. The risk managers we surveyed as part of the 2019 Global Risk Management Study realize that they fall short here, so they are urgently seeking to improve both their data-collection and analysis skills: 63 percent are urgently improving their ability to collect enterprise-wide data, and 66 percent are honing their ability to analyze it.

of our study respondents expect to use marketing data to support their risk management activity in two years’ time, but only 39 percent do so today.

57%



Which threats are our cohort of 255 bank risk executives most concerned about? We asked risk managers as part of Accenture’s 2019 Global Risk Management Study, and found them concerned about the old and the new.

Top of the list is financial crime. Credit risk is second, and evolving regulation and cyber threats are joint-third.

Risk leaders have grappled with these threats for years. But the nature of each of them is now changing, which demands new responses. Traditional risks have morphed into more challenging threats, in part due to the banking ecosystem being in flux. Gone are the days when customers purchased all of their banking services from large household names; new entrants, open banking regulation and advances in technology mean that the heritage industry players now face stiff competition from challenger banks and FinTechs (financial technology firms) for an increasing scope of products and services.

This creates a long-term strategic threat in the form of loss of market share. But it also causes immediate vulnerabilities that make financial crime and cyber attacks harder to detect and prevent.

This report looks at the most pressing risks, explores how threats are changing, and sets out a way for banks to respond.



Financial crime: a disaggregated ecosystem exposes new vulnerabilitiesSurveyed banks pinpoint financial crime as their top concern (see Figure 1).

SECTION 1


That is no surprise: Every year, banks have to invest millions in anti-money laundering (AML) and know-your-customer compliance. Research puts the total figure at $25bn annually for U.S. financial services,1 and at $20bn annually in Europe.2

Those that don’t make this investment also run the risk of incurring significant regulatory fines and reputational damage. Costs aside, risk and compliance procedures implemented to prevent financial crime can themselves create a risk of adding too much friction to the customer journey, whether it be the identification requirements for opening a new bank account or credit card transactions that are declined due to fraud concerns.

This all represents a huge headache, but it is not necessarily new. So why is financial crime the top worry today?

Financial crime, including AML & fraud

Credit risk

Evolving regulation

Increasing frequency & sophistication of cyber threats

Customer interest in technology-enabled offerings

Emergence of non-traditional competitors

Shifts in the macroeconomic variables

Open banking models

Impact of geopolitical change in key regions

Maturity of the business cycle

Growth in sub-prime

Retirement of LIBOR

49%35%

29%

29%

25%

20%

19%

15%

13%

13%

11%7%

Financial crime and credit risk cause greatest concern

Thinking specifically about the banking industry, which of the following areas are currently causing your business the greatest amount of concern?

Figure 1. Areas of greatest concern to the banking industry

Source: Accenture 2019 Global Risk Management Study


Section 1 Financial crime: a disaggregated ecosystem exposes new vulnerabilities

Highly confident

Only 11 percent are highly confident in managing the impact of financial crime

Slightly confident

Neither confident nor unconfident

Not very confident

Not at all confident

32%

29%

27%

1%

11%

How confident are you that your risk function is set up to fully support your business in managing threats related to financial crime?

Put simply, financial crime is becoming more complex. Today, bad actors use sophisticated cyber attacks and seek to exploit gaps in the increasingly complex banking ecosystem to perpetrate financial crime.

In parallel, one effect of open banking and the rise of FinTechs is that customers spend less time interacting directly with their banks. This creates more challenges for institutions to build up a picture of ‘normal behavior’ and to spot abnormal activity that could be a sign of financial crime.

No wonder only 11 percent of study respondents are highly confident in their ability to help their businesses mitigate the impact of financial crime (see Figure 2).


Figure 2. Level of confidence in managing the impact of financial crime



Bots, not bodiesBanks should invest more to stay on top of this increasingly bewildering threat. But simply increasing headcount to do more of the same won’t work. Instead, they are encouraged to do two things.

First, they should explore how smart technologies such as AI and machine learning can assist in detecting and preventing financial crime. We know that only 12 percent of surveyed risk functions use machine learning, but it could be invaluable in spotting the anomalies in data that might indicate financial crime. They can also learn patterns in data—such as a known risk entity combined with an obscure structuring arrangement—that indicate malicious activity, and flag when they occur.

To be effective, this should take place in real time in multiple channels across the enterprise. Of course, firms should strike the right balance between limiting fraud and not introducing significant friction into the customer experience.

But these tools are only as good as the data that feeds them. Unless banks devote effort and resources into cleansing and synthesizing their data, these technologies could spit out false positives. So, significant investment in data should accompany investment in analytical tools.

Second, risk managers should reconsider how financial crime risk is managed. Threats are now appearing at the intersections of previously discrete risks, so a siloed approach—where specific teams manage individual threats—won’t work.

Instead, risk teams should explore a ‘hub and spoke’ model. The ‘hub’ provides centralized expertise and oversight, and the spokes specialize in specific categories of financial crime.

Only 12 percent of surveyed risk functions use machine learning.

12%



“The banks that keep adding more bodies to tackle the problem in the same old way are also the slowest to respond to the changing risk environment. It becomes increasingly expensive and complicated if you don’t invest in data and analytics, aren’t ultra-proactive around the business challenge, and don’t drive the workforce to be more proactive about risk, problems will persist and mount.”Steve Culp Senior Managing Director, Accenture Financial Services Management Consulting and Finance & Risk



Credit risk: a new way to tackle an old foeCredit risk has existed for as long as banks themselves. Today, it is banks’ second greatest concern, and only 13 percent of respondents are highly confident in their ability to manage this risk.

SECTION 2


This is unsurprising, given the recent surge in global debt levels. According to the Institute of International Finance, global debt currently stands at its second-highest dollar level on record following an unexpected rise in the first quarter of 2019.3

How can banks better manage credit risk? One way is to deploy automation, AI, and other smart technologies to assess credit risk—whether in relation to a mortgage, credit card loan, or other loan. These technologies can be used to validate credit risk models or even permit credit decisioning at the point of sale. Of course, automation should be introduced responsibly and should not bake biases into credit decision-making.

But while some forward-thinking financial institutions are using smart technologies extensively to help assess credit risk, the majority of banks still employ large teams to manually analyze loan applications. Smart technologies can reduce the cost and improve the accuracy of this process.

Technology aside, there are other ways to tackle credit risk creatively. Some leading banks, for instance, are widening the spectrum of criteria they consider when evaluating credit risk—firms’ cyber vulnerabilities is one example of a new consideration.

“Has the way that banks manage credit risk really changed in the last five years? While some progress has been made, the answer for most is ‘no’. AI and intelligent automation bring benefits to do this, like greater efficiency and effectiveness, while adding to existing human capabilities.” Steve Culp Senior Managing Director, Accenture Financial Services Management Consulting and Finance & Risk


Section 2 Credit risk: a new way to tackle an old foe

AI tools ease compliance with new regulationThe post-crisis tidal wave of financial services regulation has passed, but banks surveyed as part of the 2019 Global Risk Management Study still cite evolving regulation as their joint-third most pressing concern, alongside cyber threats.

SECTION 3


Why is regulation still such a concern? For a start, there is the cost. Banks have invested significantly in complying with privacy regulations such as the General Data Protection Regulation (GDPR), and are vulnerable to huge fines if they do not comply or suffer a significant data breach. Then there is increased supervision of banks. Rather than just laying down the law, regulators are now more proactive in checking compliance and requesting data that demonstrates compliance.

That is all taking its toll: Just 10 percent of surveyed banks are highly confident in their ability to manage regulatory risk.

How can regulatory risk be managed more effectively? The first step is to clarify where the balance of responsibility lies between the first and second lines of defense for designing and testing the risk controls adopted in response to new regulation.

In parallel, risk managers should investigate and deploy some of the latest tools and work processes that identify and then assess the consequences of regulatory changes.

Indeed, we have observed that leading risk functions have deployed AI and machine learning-based technologies that scan speeches, news outlets and regulators’ websites for information that indicates that new regulation is being considered. These tools then track proposed regulation as it passes into law. When it is, they scan, synthesize and de-duplicate relevant regulatory text before it is ingested into the organization, where it is analyzed in order to create actionable objectives. This approach has the added benefit of creating an audit trail of how banks apply new rules.

Banking risk managers should also get better at engaging with regulators. As regulators ask for more and more datasets, risk teams are expected to improve their ability to produce data and analytics on demand. And effective engagement is consistent engagement: Banks should look at their internal organization and decide who will be responsible for working with regulators so that a consistent response is provided.

Risk functions should also demonstrate data transparency and traceability to regulators. In the future, they may have to articulate how their organizations are deploying technologies such as AI responsibly so that certain sections of society are not discriminated against.

One simple practical step that can be taken to bolster relations is to invite relevant regulatory stakeholders to observe the disruptive work that is happening at innovation labs.


Section 3 AI tools ease compliance with new regulation

“Risk functions have to improve how they engage with regulators. Many need to develop the capability to provide data on request more efficiently, for example through regulatory APIs to improve transparency.”Rafael Gomes Managing Director, Accenture Financial Services Finance & Risk


Section 3 AI tools ease compliance with new regulation

Combatting cyber threats in a digital, open banking eraThe increasing frequency and sophistication of cyber threats is surveyed as banks’ joint-third greatest risk.

SECTION 4


It is there because of the relentless pace of bad actors’ innovation and the financial and reputational damage that a major attack can inflict on an organization.

Only 9 percent of risk managers are highly confident in their ability to manage cyber attacks (see Figure 3). That is partly because the methods of attack constantly change, but also because the new banking ecosystem has introduced cyber vulnerabilities.

For example, the advent of open banking, which requires banks to open up their systems and data to third parties, entangles the two together like never before. As a result, banks should no longer just protect their own networks; they should maintain cyber resilience across the entire ecosystem.


Figure 3. Level of confidence in managing the impact of cyber attacks

Highly confident

Only 9 percent are highly confident in managing the impact of cyber attacks

Slightly confident

Neither confident nor unconfident

Not very confident

Not at all confident

32%

33%

26%

0%

9%

How confident are you that your risk function is set up to fully support your business in managing threats relating to the increasing frequency and sophistication of cyber attacks?


Section 4 Combatting cyber threats in a digital, open banking era

Smart tech holds promise, but don’t forget the basicsHow can banks foster cyber resiliency? With their huge potential to, for example, detect and classify malware or to identify suspicious activity across the network, new technologies such as AI and machine learning offer one answer.

However, only 43 percent of banks surveyed as part of Accenture’s 2018 State of Resilience Study use machine learning and AI for cyber security.4 That might be a disappointingly low proportion, but it does offer immediate scope for banks to improve their cyber resiliency by deploying sophisticated technology.

Yet there is work to do first. These technologies should only be deployed once the basics have been implemented:

The organization should train its people to spot malicious activity, such as phishing; categorize its most important data; and make sure that this data is protected.

Banks should also make sure that their ecosystem alliances are getting the cyber security basics right. Only 38 percent of the State of Resilience banking respondents hold their alliances to the same cyber security standards as themselves,5 so they should prioritize a collaborative approach to getting cyber defenses up to standard.

Only 43 percent of banks use machine learning and AI for cyber security.

43%



“Previously banks looked at risks in silos. But new threats are emerging at the intersection of things like cyber attacks, money laundering and open banking, for example. To free up capacity to explore what’s new, banks should take steps to standardize, automate and even outsource the management of some of the more established risks.”Rafael Gomes Managing Director, Accenture Financial Services Finance & Risk



Don’t overlook LIBOR retirementThe 2021 retirement of LIBOR and transition to other interbank offered rates (IBORs) may not pose an immediate threat that is of the same magnitude as other risks discussed in this report, but it can’t be ignored.

SECTION 5


Whether it is the risk of basis exposure, the sheer effort required to update LIBOR provisions in contracts, or managing conduct risk, LIBOR transition is a major undertaking that demands proactive risk management.

Non-risk business leaders acknowledge this and have called on risk teams to assist. Almost three-quarters of financial services businesses surveyed in Accenture’s 2019 LIBOR Survey say risk management and front-office quant teams are of greater importance in supporting LIBOR transition.6

But our Global Risk Management Study reveals that this call has, to date, gone unanswered. Tellingly, just 7 percent of banking risk managers cite LIBOR retirement as a top-three concern. They have not even recognized it as a major threat, let alone started to act.

Now it is time for risk leaders to step up. Instead of simply recalibrating risk models, they should work collaboratively with other business functions to unearth the impact on the entire business.


Section 5 Don’t overlook LIBOR retirement

Uncover the hidden risks of LIBOR transitionWhat exactly should risk teams do to help prepare? The first step is to identify and then quantify exposure to specific LIBOR risks. LIBOR exposure lurks in hidden corners of businesses’ operations, so risk managers should be thorough in their approach.

Second, risk managers should establish a robust framework to assess and manage the risks associated with the transition. This should cover how the transition impacts a range of risks, including foreign exchange (FX) risk, liquidity risk and operations risk. Importantly, risk teams should assess how these risks materialize both internally and externally. A poorly timed and ill-executed transition strategy—both internally and across the entire financial services industry—could potentially leave firms with illiquid assets, higher capital charges and significant operational risk.

Conduct risk should also remain in focus. Whether in relation to client interactions or contributing to the new benchmark, risk managers should devise measures to protect clients and markets from abuse. This could involve enhanced training controls or market education programs.

In parallel, risk teams should review new and amended products to make sure they do not adversely impact clients. The outcome of this, and the fact that it has taken place, should be clearly communicated to customers and built into outreach and negotiation strategies.



LIBOR retirement is fast approaching. Risk managersshould act quickly or be left behind as the rest of the business prepares for the transition.



How banks can manage today’s major threatsThere is no one-size-fits-all approach to mitigating today’s risks, and there are no quick wins. The picture is intricate and changing fast.

SECTION 6


1. Map out risk interdependenciesBanks can no longer think about risks as isolated, distinct threats: Today, everything is connected. Financial crime risk has become more complex as a result of open banking and growing cyber security threats. And cyber threats themselves are now intertwined with data privacy and reputational risk. The list goes on.

Risk managers should first map out how risks are related before they can organize their teams to manage them. For example, it is impossible to adequately manage financial crime without an understanding of cyber security risk and open banking.

That interdependence has one obvious ramification: Risk teams should not operate in silos. Instead, they should draw on expertise from across the function to truly understand how threats are interlinked.

2. Prioritize data hygieneSmart analytical technologies such as AI and machine learning can help risk functions to detect threats. But they won’t work if the data that feeds into them is not clean or synthesized. For example, these tools produce a huge number of false positives if banks use different naming conventions for customers and suppliers in different departments.

It is impossible to standardize data across the entire organization. But risk managers should still implement the necessary structures and governance controls to keep data as clean as possible. AI tools can also be deployed to cleanse data.

But there are a number of steps that risk managers can take to effectively position their business to cope with new threats. These are:


Section 6 How banks can manage today’s major threats

“For AI, machine learning and automation to take effect, you need consistency of data. Banks continue to struggle with this due to both the significant volumes and sources of data across various systems as well as challenges with the governance and ownership of the data. It remains a critical issue to resolve before you can scale and effectively make use of smart technologies.”

Steve Culp Senior Managing Director Accenture Finance Services Management Consulting and Finance & Risk

3. Right-size new product compliance to speed innovationTraditional banks face new competition on all fronts. In response, many have ramped up their own innovation efforts and created innovation labs that experiment with new products and services.

The risk function should be called upon at some stage to approve new products, and it is here that tensions can surface. The product team is keen to release its new product to the market, but the risk team might have hundreds of compliance checks that have to be processed first.

Agility is key. Risk teams should only process the checks that are absolutely essential at the early stages of product development. An overbearing approach incorporating unnecessary checks can stifle innovation and delay new product releases.

The earlier the risk function involves itself in new product development the better. By providing early advice, mistakes during the product development stage can be avoided. This in turn can hasten risk and compliance checks when products are developed.

This is not just about undertaking checks at the right time, but also about automating manual work. For example, risk teams spend a lot of time checking the risk profile of new products and making sure that risky solutions are not targeted at risk-averse clients. Today, much of that work can be automated.


Section 6 How banks can manage today’s major threats

Define your sphere of controlUnknown, interconnected risks are multiplying at a faster rate than ever before. It is impossible to try and control all aspects of the complex business environment in which banks operate, and the faster that risk leaders acknowledge this fact, the better.

CONCLUSION


Those who can draw a clear line between the factors they control and the factors they cannot are taking an important step towards focus and prioritization. Equally, the risk management function should focus its efforts and energy on preparation and planning, rather than on prediction—so irrespective of the cause of the issue, the bank is ready to respond effectively to mitigate the impact.This is how to manage your sphere of control.

Firstly, risk functions should prioritize what matters most. Taking a holistic view of the risk environment, they should have clear criteria to gauge the value of their assets and assess which are most critical to protect.

Secondly, leaders should prepare their function by allocating resources smartly, embracing the latest tools and technologies, and upskilling their people so they can wield them reliably.

Finally, risk leaders should build a more proactive function, diligently scanning the horizon for the next threats, as risks evolve and approach in unfamiliar forms. Rather than plan for specific eventualities, they should continue to prepare for disruption—looking outwards in every direction.


Conclusion Define your sphere of control

1 “Anti-money laundering compliance costs U.S. financial services firms $25.3 billion per year, according to LexisNexis Risk Solutions,” Cision PR Newswire, October 10, 2018. Access at: https://www.prnewswire.com/news-releases/ anti-money-laundering-compliance-costs-us-financial-services-firms-25- 3-billion-per-year-according-to-lexisnexis-risk-solutions-300728586.html

2 ”Europe is losing the fight against dirty money,” Politico, April 5, 2018. Access at: https://www.politico.eu/article/europe-money-laundering- is-losing-the-fight-against-dirty-money-europol-crime-rob-wainwright

3 “Global Debt Quickened in First Quarter, Outpacing World Economy,” Bloomberg, July 15, 2019. Access at: https://www.bloomberg.com/news/articles/2019-07-15/global-debt-accelerated-in-1st-quarter-outpacing-world-economy

4 “2018 State of Cyber Resilience for Banking & Capital Markets,” Accenture 2018. Access at: https://www.accenture.com/us-en/insights/financial-services/ 2018-state-of-cyber-resilience

5 Ibid

6 “Accenture 2019 LIBOR Survey,” September 2019

References


https://www.prnewswire.com/news-releases/anti-money-laundering-compliance-costs-us-financial-services-firms-25-3-billion-per-year-according-to-lexisnexis-risk-solutions-300728586.html



https://www.politico.eu/article/europe-money-laundering-is-losing-the-fight-against-dirty-money-europol-crime-rob-wainwright/

https://www.politico.eu/article/europe-money-laundering-is-losing-the-fight-against-dirty-money-europol-crime-rob-wainwright/

https://www.bloomberg.com/news/articles/2019-07-15/global-debt-accelerated-in-1st-quarter-outpacing-world-economy



https://www.accenture.com/us-en/insights/financial-services/2018-state-of-cyber-resilience




Fred Kim Fred Kim is a Managing Director—Accenture Financial Services, Finance & Risk, and leads the Finance & Risk Banking group in North America. Based in Charlotte, Fred has over 20 years of experience in banking, working with some of the world’s leading financial institutions. With his functional experience in commercial and consumer lending, risk management, process re-engineering, operating model design and risk data management, Fred guides and helps risk management executives transform their enterprise capabilities with innovative strategies and digital solutions. Fred has a BA and an MBA from the University of Michigan.

Rafael Gomes Rafael Gomes is a Managing Director—Accenture Financial Services, Finance & Risk. Based in London, he is the Regulation and Compliance Lead for Financial Services Consulting in the UK and Ireland. Rafael’s client engagements cover regulatory response, conduct and ethics, and behavioral analytics in banking and capital markets. He is a recognized thought leader in compliance and a former recipient of the Robin Cosgrove Global Prize for Ethics in Finance for work based on his PhD in conduct risk and regulatory relations.

About the authorsSteve Culp Steve Culp is a Senior Managing Director—Accenture Financial Services, Management Consulting and the Finance & Risk practice. Based in Chicago, Steve has more than 25 years of experience working with clients across multiple geographies to define strategy and execute change programs across risk management and the broader finance function. His current focus is to work with client leadership to help them advance their business performance through innovative strategies, processes and change. Steve holds a Bachelor of Science in Finance and Economics from Northern Illinois University and earned an Executive Master of Business Administration degree at Kellogg in 1999.

Acknowledgments

Contributors: Sam Regan, Andrew Solow, Tales Lopes and Jeff Jamison


About the research

The Accenture 2019 Global Risk Management Study is the sixth edition of our study first published in 2009. It is based on a telephone survey (computer-assisted telephone interviewing, CATI) of 683 senior risk management executives conducted by Longitude Research Ltd on behalf of Accenture between March 2019 and April 2019.

Survey participants were sourced from around the world and work in three sectors within financial services: banking (255 participants), capital markets (201 participants), and insurance (227 participants).

To complement the survey data, Accenture applied natural language processing to a database of earnings calls and conference transcripts from 2010 to 2018 in order to verify financial services firms’ most pressing risks. This analysis covered 225 firms in banking, capital markets, and insurance. It identifies the risk types being addressed, the intensity of the discussion, and how this changes over time.

For each of the 10 risk types probed, a set of keywords were developed to generate a risk frequency. This frequency was then divided by the total number of words available for each company across all earnings calls and conference transcripts to arrive at the proportion of transcripts devoted to a risk overall and over time. This measure was then log-transformed to smooth out extreme values and rescaled to allow relative comparisons across risk types and industries.

Finally, a normalization process was applied to generate an index of values between 0 and 100 for each company-risk type, where 100 indicates the highest intensity of discussion around a risk and 0 indicates no discussion. The normalized measures are relative in nature and allow comparison of the intensity of discussions across topics as well as over time. When presenting the results, financial, operational, and regulatory risks were grouped into a ‘traditional risks’ category.


About AccentureAccenture is a leading global professional services company, providing a broad range of services and solutions in strategy, consulting, digital, technology and operations. Combining unmatched experience and specialized skills across more than 40 industries and all business functions—underpinned by the world’s largest delivery network—Accenture works at the intersection of business and technology to help clients improve their performance and create sustainable value for their stakeholders. With more than 492,000 people serving clients in more than 120 countries, Accenture drives innovation to improve the way the world works and lives. Visit us at www.accenture.com

ContactAccenture Finance and Risk www.accenture.com/financeandrisk

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This document is intended for general informational purposes only and does not take into account the reader’s specific circumstances, and may not reflect the most current developments. Accenture disclaims, to the fullest extent permitted by applicable law, any and all liability for the accuracy and completeness of the information in this document and for any acts or omissions made based on such information. Accenture does not provide legal, regulatory, audit, or tax advice. Readers are responsible for obtaining such advice from their own legal counsel or other licensed professionals.

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The sphere of control - Financial Services · 2019-11-28 · The sphere of control. Contents INTRODUCTION Evolving ecosystems, evolving threats 3 SECTION 1 Financial crime: a disaggregated