1. Joe Dunphy VP Product Management - Fenergo
Managing the impact of Regulatory Change on bank processes and technology
Joe Dunphy
VP Product Management - Fenergo

2. About Fenergo Fenergo Overview
Client Lifecycle Technology company focused on legal entity data management, regulation and client & account related workflows for Investment, capital market and private banks.
Enabling financial institutions to ensure global compliance with regulations such as KYC, AML, Tax (FATCA & CRS), Derivative Reform (Dodd-Frank, EMIR, Canadian & APAC deriv. rules), through a community based approach to solving regulation.
32 FIs live on our software, with 18 current active FI implementations. We have 1 agenda: To serve the Client Lifecycle Mgmt. space and become “The Standard”.
The Fenergo business has grown on avg. 100% yearly for the past four years, culminating in Insight Ventures and Aquiline Partners investing €75m to fund growth in the summer of 2015.
Headquartered in Dublin, with offices in the New York, Boston, London, Singapore, Abu Dhabi Sydney and Wroclaw. Fenergo are a specialist team of 300 Entity Data, KYC, Tax, Derivative and COB technology specialists.

3. Counter-Terrorism/AML
Regulatory Storm
Counterparty Risk
Global Tax
Counter-Terrorism/AML
Market Abuse
Volume of New Requirements
OTC Derivatives, BCBS, EMIR, FATCA, CRS, 4th EU AMLD, Patriot Act, Margin, MiFID II, GDPR
Managing Regional Variations
Scope Overlap: e.g. Dodd-Frank, Canadian Derivatives, EMIR, OTC Asia Pac
Implementation Timeframes
Tight timeframes, changing scope, large areas of business impact
Cost and Service Impacts
Increased customer requirements, longer onboarding timeframes, inefficient legacy processes
FATCA Global Tax; 3rd AMLD th AMLD; MIFID MiFID II
Competing Challenge: COO, Head of Compliance, CEO, Front Office

4. Ongoing Regulatory Change
Ever growing regulatory environment

5. How are banks addressing the challenge?
Consolidated delta-based solutions
Integrated Lifecycle Model
Rules-based configuration
Centralisation of Functions
Community approach

6. Re-use: Manage the Delta
AML / KYC
Dodd Frank
FATCA
CRS
EMIR….
Legal Entity Name, Address, Entity Type, Entity Role & LEI
Legal Entity Name, Address, Entity Type, Entity Role & LEI
Entity Associations & Party Relationships
Traded Products, Accounts & Booking Entities
Documents: Cert of Incorporation, Beneficial Ownership, Trading Agreements
PEP Data
EBC Protocol 1.0
GIIN
Tax Residency
EMIR Classification
Sanctions Screening
Swap Docs 2.0
FATCA Classification
Self Certification
Clearing Exemption
Risk Scoring
DF Protocol& Compliance
FATCA Docs
W8\W9
Reportable Jurisdictions
EMIR Reporting Req
Single & Consolidated
Party Data Regulatory Store

7. Integrated Client Lifecycle Management
Bank trading platforms
Entity Data
CRM
Client Lifecycle Events
New client
Existing
Client
Reviews
Maintenance
Client Offboarding
New Product
Account
Fund
KYC Utilities
Regulatory rules and classification framework
Dodd Frank
EMIR
MAS
HKMA
ASIC
FATCA
KYC
PEP / Sanctions
AML
Risk assessment
Market access KYC
Consume
Bank’s
Firewall
AML Data
Understand
CRS
Route
Entity Data Management
Client
Data / SCD
Hierarchies
KYC / AML
Data
Classification
Account Setup
Industry Data
ISDA AMEND
Reporting Platform
SSI’s
Operational Data Management
Authorised Actions
Trading Agreements
Contract Management
Managed Accounts
SSIs 8 7

8. Rules Engine Execution
Client Lifecycle  Driven by Bank App UI or Fenergo UI
Request
Initiation
OB and
KYC
Credit
Ops
Legal
Workflow & Rules Engine (Tightly Coupled)
Decision Criteria
LE Type
LE Role
Traded Product
Booking Point
Jurisdiction
KYC
Risk Rating Factors
SDD Vs EDD
KYC question set
Classification
MLRO
Credit
Credit Required: Y\N
Routing rules\limits
Operations
Checklists
Documents
Approvals
Legal
ISDA Required
Compliance checks
Business Rules Engine
Decision Table
Workflow
Table
Documents
Classification
Types
Details

9. Centralisation The Big Picture Challenges Technology Toolset
Shared/managed service approach
KYC and AML directives
Reporting obligations – CRS / OTC
BCBS 239
Data Residency Requirements
Confidentiality
Countries Offering a Comparable Level of Protection
Data Masking
Data Access Restrictions
Protection of Associated Entities
Jurisdictional rules
Personally Identifiable Information
Localisation
Local data protection and privacy laws
Lack of uniformity
Non-contracted 3rd parties
Splashscreen validation
Confidential Clients / Confidential Deals
Inheritance

10. This design is reviewed and approved at the Forum
Community Approach
Regulatory Lifecycle – a community approach
Monitor
Monitor upcoming regulatory change and tracks via the regulatory roadmap.
The roadmap is shared with the Forum and timelines, approach and content is debated and validated
Initial Proposal
Regulatory analysis team create initial proposal for review and debate at Forum.
The proposal is refined in line with the Forum direction
Detailed Design
Regulatory team work with analysts and nominated Bank SMEs to produce detailed product design specifications.
This design is reviewed and approved at the Forum
Product Delivery
Deliver the new functionality as an update to the product / systems in advance of the regulatory deadlines.
(Bank SMEs remain involved for review and direction throughout the delivery process)
Implementation
The new functionality is rolled out for implementation to allow adherence to the new regulatory requirements.

11. There is no neutral option – every decision makes it better or worse
Final Thoughts
There is no neutral option – every decision makes it better or worse
Look beyond the immediate tactical requirements of each regulation to create an extendable strategic approach
OTC
Patriot Act / 4th AMLD
KYC
AML
FINRA
BCBS
239
Regulatory Framework
Risk
Ass.
TAX
Extendable Framework
FATCA
MiFID
Client
Classifications
Flexible regulatory Framework supporting all regulatory rules & classifications
APAC OTC Deriv. Reform
CRS / CDOT

12. Thank You Visit Us on Stand #12 Thank You e: info@fenergo.comw:
or follow us on:
Global Headquarters:
Ormond House, Ormond Quay, Dublin 7, Ireland
United Kingdom:
200 Aldersgate, London, EC1A 4HD
North America:
5th Floor, 1177 Avenue of the Americas
New York, NY 10036
North America:
470 Atlantic Avenue, Suite 4051 Boston, MA 02210
APAC:
Level 57, MCL Centre, Martin Place, Sydney, Australia, NSW 2000
Thank You