The Future of Wealth Management

PwC’s 4th FS-Talk

Wealth managers are challenged by shifting client segments and disruptive technologies PwC experts discuss the key success factors for wealth managers today. Private client re-segmentation makes value-added services more important. Demands on relationship managers are increasing. Operations are under pressure to deliver higher efficiency. Listen in for pointers of where the challenges are and which technologies provide opportunities to gain a competitive edge.

Watch the latest video of our FS-Talk:

Get in contact with the speakers:

Dieter Wirth
Partner / Financial Service Leader
+41 58 792 4488
dieter.wirth@ch.pwc.com

Marcel Tschanz
Partner Advisory
+41 58 792 2087
marcel.tschanz@ch.pwc.com

Marcel Widrig
Partner / Private Wealth Leader
+41 58 792 4450
marcel.widrig@ch.pwc.com

SWIFT Customer Security Programme – mandatory specifications to protect your local SWIFT infrastructures

The growing number of cyber-attacks, including those on the local infrastructures of SWIFT participants, has prompted SWIFT to create a security programme for its participants in order to fight together against cyber threats.

SWIFT published its Customer Security Programme in April 2017. It defines specific requirements to be met by all connected participants. The programme aims to improve the exchange of information within the SWIFT community, to ensure a high level of security for the local SWIFT infrastructure of participants, and to put in place an assurance framework to counter the ever growing number of cyber threats and strengthen the ability of SWIFT participants to combat cyber-attacks.

SWIFT Customer Security Programme

The programme calls upon all SWIFT participants to implement a control and assurance framework. The control framework consists of a set of 16 mandatory and 11 advisory security controls. The controls are based on existing SWIFT security guidelines, and are in line with good practice standards such as NIST, ISO/IEC 27002 and PCI-DSS. The mandatory controls establish a security baseline for the entire SWIFT community. SWIFT also recommends implementing the advisory controls to provide optimal protection for local SWIFT infrastructures.

Demands placed on SWIFT participants

The SWIFT Customer Security Programme will come into force on 1 January 2018. As well as applying to financial service providers, it is also valid for all companies that participate in the SWIFT network. Before the introduction of the programme, each SWIFT participant must conduct a self-assessment and notify SWIFT of its status regarding compliance with the controls (by the end of 2017). From 2018, all participants must confirm their compliance with controls on an annual basis. This confirmation can be provided via a self-assessment (self-attestation), internal audit (self-inspection) or external audit (third-party inspection). Participants are free to choose the type of confirmation they wish to submit. SWIFT will however also carry out regular spot checks of confirmations via internal or external audits for quality assurance purposes.

SWIFT participants must consider the following points in particular:

  • Should only the mandatory controls be implemented, or also the advisory ones?
  • How should the assurance framework be structured? Is self-assessment sufficient, or should an internal or external audit be conducted on a regular basis?
  • Should the status regarding compliance with controls be made public to other SWIFT participants?
  • How can it be ensured that controls continue to be adhered to in the future?

The support we offer you

SWIFT Readiness Assessment

We can help make sure you comply with the SWIFT requirements by 1 January 2018 by assessing your current status and highlighting any gaps.

SWIFT control support

We can provide support for the implementation of controls by means of a post-implementation review.

SWIFT compliance confirmation

We can assist you with your annual confirmation of compliance with SWIFT requirements.

Please feel free to contact our experts if you are interested in the topic.

More information

Contacts

Jens Probst
Director, Systems & Process
Assurance
+41 58 792 29 59
jens.probst@ch.pwc.com

Claudia Hösli
Senior Manager, Specialist Cyber Security
+41 58 792 14 85
claudia.hoesli@ch.pwc.com

Marco Schurtenberger
Senior Manager, Specialist Cyber Security
+41 58 792 22 33
marco.schurtenberger@ch.pwc.com

CRS Updates May 2017

Second Edition of the OECD Standard for AEOI Released

On 27 March, 2017, the OECD published the second edition of the standard for Automatic Exchange of Financial Account Information in Tax Matters (“AEOI”). This newly released edition replaces the first edition of the standard for AEOI from July 2014.

The vast majority of the standard for AEOI remains unchanged relative to the first edition. In the second edition, Annex 3 “Common Reporting User Guide” is updated, as it now contains additional technical guidance on the handling of corrections and cancellations within the CRS XML Schema, including a revised set of correction samples.

Please refer to the following link for access to the second edition of the standard for AEOI: http://www.oecd.org/ctp/exchange-of-tax-information/standard-for-automatic-exchange-of-financial-account-information-in-tax-matters-second-edition-9789264267992-en.htm

Facility to Disclose CRS Avoidance Schemes Launched by OECD

On 5 May, 2017, the OECD launched a disclosure facility on the Automatic Exchange Portal allowing parties to share information on potential schemes, products, and/or structures that may be used to circumvent the Common Reporting Standard (“CRS”).

Parties are able to fill out a form through the Automatic Exchange Portal to describe any identified loopholes or schemes that may be used for avoiding the CRS. The form asks for a description of the scheme, information on how actively it is used, and a list of the countries or regions where the scheme is used . The OECD then systematically analyzes the received information on the reported schemes to assess the risk they present to the overall integrity and effectiveness of the CRS. If required, the OECD uses the acquired information to take appropriate courses of action. Parties may fill out the forms on an anonymous basis.

 

OECD Automatic Exchange Portal’s form

Contact

Christoph Schaerer
PwC Schweiz
+41 58 792 4282
christoph.shaerer@ch.pwc.com

QI renewal deadline is fast approaching (31 March) and IRS publishes new FAQs regarding QDD application

QI Renewal Deadline

Qualified Intermediaries (QIs) that wish to renew their QI Agreements with an effective date of 1 January 2017 are reminded that the application for their renewal is due by 31 March 2017.  Renewing by 31 March 2017 will ensure that there is a seamless transition from the old QI agreement to the new 2017 QI Agreement.

The application must be submitted online through the new IRS QI Portal.

For more information about the application process and the use of the portal, please see our PwC Tax Insights publication.

New FAQs regarding QDD application

On 17 March 2017, the IRS published new Frequently Asked Questions (“FAQs”) that provide additional details regarding the completion of the application questions for QIs that wish to apply to be Qualified Derivative Dealers (“QDDs”) for 2017.  These FAQs are published on the FATCA FAQ website under the Qualified Intermediary heading.  There are a total of eleven FAQs (beginning with #10) posted by the IRS that answer a variety of questions regarding the completion of the application for QDD status.

QI’s that wish to be QDDs with an effective date of 1 January 2017 must submit their applications on or before 31 March 2017 through the online QI Portal.

SuisseTax Online Portal Open for AEOI Registration

As of this week, ESTV SuisseTax, the Swiss Federal Tax Administration’s online portal, has opened its AEOI registration function for reporting Swiss Financial Institutions (“FIs”). Reporting Swiss FIs must register by the end of 2017 for an initial AEOI data exchange in 2018.

Please note that a registration for AEOI purposes is only possible via the online portal. Swiss FIs can enter the ESTV SuisseTax portal by referring to the following link:  https://www.estv.admin.ch/estv/de/home/estv-suissetax/estv-suissetax.html.

The Swiss Federal Tax Administration is expecting to provide a data exchange test phase for reporting Swiss FIs in the summer of 2017.

Please refer to the link below for the official media release: https://www.admin.ch/gov/de/start/dokumentation/medienmitteilungen.msg-id-65920.html

Financial services businesses may not be eligible for the European Cost Sharing exemption – opinion of the Advocate General in DNB Banka (C-326/15) and Aviva (C-605/15)

Summary

The Advocate General (“AG”) issued its opinion on the application of the cost-sharing exemption (“CSE”) provided by article 132(1)(f) of the VAT Directive in two cases regarding financial services providers (i.e. banks and insurance companies). The opinion of the AG is not in line with the position of the EU Commission and the discussions in various meetings of the VAT Committee in 2010, 2014 and 2015 and it also appears not to be in line with the pending infringement procedures of the EU Commission against Luxembourg (C-274/15) and Germany (C-616/15).

Cost Sharing Exemption

The CSE allows businesses to come together and pool resources as a means of sharing these resources between each other free of VAT (as opposed to procuring services externally with VAT) on the grounds that these resources are directly necessary for the activities of the members of the cost-sharing group. In order to benefit from this exemption, the group needs to consist of entities engaged in VAT-exempt or non-taxable activities and the supplies need to be made by the group to the members at cost.

Currently, the majority of the EU member states allow the application of the CSE to financial services businesses.

Position of the AG

  • The CSE should apply to services supplied by the group to its members and not vice versa (i.e., the contribution of resources by the members of the group to the group (to the pool) is not VAT-exempt).
  • The members eligible for the application of the CSE are companies/bodies acting in the public interest (this excludes financial services businesses).
  • The CSE is only applicable to services supplied between the group and its members established in the same EU member state (i.e., the CSE cannot apply on a cross-border basis).

Potential implications

We anticipate that the impact on the financial services sector will be significant if the Court of Justice of the European Union (“Court”) decides to follow the opinion of the AG. Specifically, the cost of the procurement of services for the benefit of the whole group will be higher (because of irrecoverable VAT). This would mean that financial services businesses would have to consider other available options to manage the VAT costs on the shared services and/or resources. One of the options could be a set-up of a cost-pooling arrangement (cost-contribution arrangement as per chapter VIII of the OECD guidance 2010) to pool resources that are mutually beneficial for all participants and to share the costs of the benefits that each participant derives from the pool. Another option could be to undertake a detailed review of the services supplied between the members to confirm whether they could benefit from the local VAT exemptions.

For the present, we must wait to see if, and to which extent, the Court agrees with the AG’s opinion. However, please do not hesitate to contact us if you would like to discuss the above.

Contacts:

Tobias Meier Kern
Director Indirect Taxes
tobias.meier.kern@ch.pwc.com
+41 58 792 4369

Marcella Dzienisik
Senior Manager Indirect Taxes
marcella.dzienisik@ch.pwc.com
+41 58 792 4938

 

Good, but could do better – Key learnings from the FAFT AML&CFT Mutual Evaluation Report of Switzerland

On 7 December 2016, the Financial Action Task Force (FATF) published the results of the Mutual Evaluation Report on Switzerland, concluding their assessment performed from 25 February to 11 March 2016. The results, extending to 245 pages, make interesting reading for AML practitioners and compliance officers.

FAFT concluded,Overall, Switzerland’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regime is technically robust and has achieved good results. It would still benefit from some improvements in order to be fully effective.”

PwC  analysed the key findings and identified learnings for regulated firms together with options for regulatory development. The key learnings concern:

  1. Suspicious Transaction Reporting (“STR”)
  2. Due diligence on longstanding customers
  3. AML&CFT customer risk classification
  4. AML&CFT Risk Assessment
  5. Penalty Sanctions

Read our findings and perspective here

For more information please contact our experts

Michèle Hess
Assurance Director
michele.hess@ch.pwc.com
+41 58 792 46 67

Daniel Cicetti
Assurance Senior Manager
daniel.cicetti@ch.pwc.com
+41 58 792 23 92

Alister Smith
Advisory Senior Manager
alister.smith@ch.pwc.com
+41 58 792 47 96

Navigating change – the UK tax environment

Banks and their clients have a short time period to react to the significant changes being introduced to the taxation of UK Resident Non-Domiciled (UKRNDs). These changes are being introduced against a sea change in the industry. So what are the key things to be talking about to your clients? How can you adapt to these changes in a commercial and pragmatic way? And what actions should you and your clients be considering – both pre 5 April 2017 and over the longer term?

Watch the recording of our webcast where Alison Hill, Peter Houghton and Lisa Cornwell from PwC UK take a deeper look in to the UK tax environment, allowing you to navigate through the upcoming changes.

Youtube link to the recording

Contacts

Alison Hill,
Director, Private Client Solutions, PwC UK
alison.hill@uk.pwc.com

Lisa Cornwell,
Director, Private Client Solutions, PwC UK
lisa.cornwell@pwc.com

Peter Houghton,
Senior Manager, Private Client Solutions, PwC UK
peter.houghton@uk.pwc.com

The Client onboarding process – how to provide state-of-the-art support

At first glance, client onboarding seems to be a simple and fast process. But apart from high client expectations and tedious internal processes, increasing regulatory requirements – such as the Foreign Account Tax Compliance Act (FATCA) or the Markets in Financial Instruments Directive II (MiFID II) – have also turned it into a highly complex, customised process for every single prospective client. This could lead to banks spending weeks or even months running complex approval processes and having to let the client wait until an initial transaction can be made over the newly opened account. This leads us directly to the question of how customers, and even employees, can be supported during the process to enable a good customer experience on the one hand and efficiency gains within the company on the other.

Our clients in the banking industry have pointed out that implementation of a new client onboarding process is just one side of the coin (read our previous blog about client onboarding). The flip side is to come up with a support model that guides customers and employees through all upcoming questions during the onboarding process. Providing a consistent support model is also essential to improve the completeness and accuracy of account documentation.

PwC can support you in analysing your current support model, finding the gaps in comparison to best practice solutions, and in implementing an advanced support model into your existing, or new, client onboarding process.

In this blog, we will give you some insight into possible support solutions.

Please don’t hesitate to contact us.

Marc Achhammer
PwC, Director Advisory
+41 78 850 66 66
marc.achhammer@ch.pwc.com

Sandro Ricklin
PwC, Assistant Manager
+41 58 792 20 01
sandro.ricklin@ch.pwc.com

PwC AFME report on operational impact of Brexit on banking

AFME has recently commissioned a report from PwC, outlining the operational impacts and transformation challenges that Brexit poses to the provision of banking services in the EU.

The report, ‘Planning for Brexit – Operational impacts on wholesale banking andbrexit capital markets in Europe’ aims to provide policymakers and other industry stakeholders, both in the EU27 and the UK, with a fact-based analysis of how these challenges are likely to affect the financial services industry. To inform the study, information was gathered by PwC from previous case studies and from 15 banks spanning a range of sizes, activities, origins and legal entity structures. They include EU27 headquartered, UK headquartered and non-EU headquartered banks in broadly even measure.

Key findings of the report include:
The Brexit transformation will be highly complex for wholesale banks and contains many interdependent activities. Firms providing a significant proportion of current industry capacity will need to execute transformation programmes which will extend beyond Article 50 timescales and in many cases up to three years after Brexit has been completed; or even longer if the post-Brexit trading relationship between the EU and UK remains unresolved for a protracted period.

In executing their transformation programmes, banks will be heavily dependent upon timely approval of licenses by their new EU regulators. This represents a critical step in the implementation of new business models and is likely to occur at a time when regulators will see a peak in requests following Article 50 activation.

Banks are currently proceeding with two year tactical plans to maintain continuity of service.  However, these plans are likely to be sub-optimal for clients and market effectiveness, and will be dependent on reaching agreement about an interim business model that is acceptable to new EU27 regulators and can be put in place before the UK leaves the EU.

Read the report.

Please let us know if you are interested in discussing this.

Günther Dobrauz
Partner
Leader Legal FS Regulatory &
Compliance Services
+41 58 792 14 97
guenther.dobrauz@ch.pwc.com