INDUSTRY NEWS

No doubt that 2020 was one hell of a year. I think it’s an understatement to say that we were all blindsided by the changes to our world as we knew it. For many of us our mental health has been challenged, often to what felt like our breaking point. So much change in the world and in our personal and professional lives, which occurred so quickly.  Not only to ourselves, but our friends and family, as we all fought and continue to fight to stay financially stable, healthy and safe.  If you are here reading this then congratulate yourself, you are a survivor. We both are and that is a good thing.

 

If there is one thing that the events of 2020 caused me to do, was to reflect on some pretty important aspects of my life; such as both my personal and business relationships, my livelihood, my adult children’s livelihoods, my health and the health of my family.

 

I also took pause to reflect on those things in my life that are often easy to take advantage of or to take for granted. While 2020 was relentless in inflicting monetary consequences on both business owners and their employees, it also changed how we work with each other; less face to face and more virtual.  To be able to say “I am still standing” is not only a divine blessing but fills me with immense gratitude.

 

It is to all of you who are or have been a client, to those that believe in what I do and the services I offer, who have promoted me, referred business to me, provided a recommendation to your clients or to those who have been an often much needed resource to me personally or to a client of mine; I wish to say a heartfelt Thank you! You truly are all a blessing to me. I am still here, in business and thriving because of each of you!

 

I strongly believe that when a blessing occurs or is handed to you, not only must you acknowledge the blessing but you must celebrate it and extend the gratitude into an actionable outcome sending the positive energy you were blessed with into the Universe.

 

Therefore, to celebrate my blessings I have relaunched the Sentinence website; with a complete redesign. The relaunch of Sentinence, is the first step in a series of steps that I hope will make 2021 the best year. I look forward to doing business with all of you. May you all stay safe, and healthy. Lets work together and make good things happen!

 

Which Advisory Consulting Service to Choose

 

Anyone who has seen the Matrix knows the story. “You take the blue pill, the story ends. You wake up in your bed and believe whatever you want to believe. You take the red pill, you stay in wonderland, and I show you how deep the rabbit hole goes.”

So how does this relate to picking a consultant for compliance? There are the consultants that will take your money, hand you the blue pill and give you a package of pre-done AML manuals and/or KYC policy and procedures, RISK assessments and RISK policies (I know… Scary words) and send you on your merry way. Now, some companies with no knowledge or understanding of compliance will think great, I’m set and ready to take on the regulators and banks!

But honestly kittens (to quote the great Dame Edna) it just doesn’t work that way.   Taking the red pill will be painful and the rabbit hole can feel never ending, but it will also be educational, enlightening and take you down the path of true compliance.

Many people think compliance is its own little entity within a business. Working alone in its cubicles (where’s my stapler… I’m starting to see I am entertained far too much) reviewing documents, writing documents, spreadsheets and papers everywhere across a desk. Oh yes and those key words you hear as you pass the cubicles, policies… procedures… risk mitigation, risk assessment… risk, risk risk! Aren’t they “those people” that pop their head up when regulators or law enforcement show up at the door? Sound familiar?

But really good compliance, the compliance that the regulators and banks want to see, the compliance you want to put in place, is the compliance that touches all operations within a business and that is integrated into all of your operations. Compliance should be involved in all business decisions from sales and customer service to banking and all the executive decisions that your operation requires. Everyone in a business that utilizes a compliance department is key to the success of any compliance program. This means input and buy in from every department, and a directive from the top down because if the top level of decisions makers do not get it how will the foot soldiers get it?

This means tailor making every compliance policy and procedure and AML manual to incorporate all aspects of your business. This takes time and this takes knowledge and experience. While finding the text book smart consultant that can rattle the regulations off from memory is one way to go; choosing a “good consultant” goes beyond reciting the regulations and uses their skills on how to adapt those regulations, to interpret those regulations and integrate those regulations into your business. Compliance can be difficult and can appear to be black and white, the good consultant will find ways to work with you so that you follow the regulations and still conduct a profitable business.

A good consultant will not simply have the knowledge and understanding of the regulatory requirements and how to implement them into your day-to-day business but will have a much broader experience in business processes as a whole. Compliance and your business as a whole are co-dependent and your policies and procedures cannot be created in a bubble.

When you are looking to hire a consultant, find out if the consultant is going to really understand your business and be a partner to your business. Or will they just sell you what they can, having you skim over the fine print, hand you the blue pill cure all and walk out of your life having you fend for yourselves.

Sentinence hands out the red pill. We take the ride with you down the rabbit hole and come out on the other side, ahead of your competitors and compliant.

Sentinence

You:                          Help!! Help!! I see a wolf in the distance!!

Mediator:                 I am here to help. What is your name and what is your location?

You:                           No that’s private information I am not comfortable disclosing!

You:                          Help! Help!! A wolf is chasing me!!

Mediator:                 I wish to help. What is your name and what is your location?

You:                          No that’s private information I will not share that information!

You:                           Help! HELP! I can’t leave my house I can’t operate my business!  I won’t be able                to maintain my home, or feed my family!  The wolf is prowling outside my home, outside my business!

Help!! HELP CAN ANYONE HEAR ME??

Over the last several months I have shared countless news articles on the De-risking and De-Marketing practices global Banks are conducting to a very specific market industry; MSB’s, MTO’s, E-Money, Remittance Businesses, Online Payment Processors and Third Party Payment Processors. Businesses are being crippled, some have thrown in the towel, given up the fight and closed shop. Not only have they lost their livelihood but the numbers are significant enough that it has been foreseen to negatively impact the global economy. Some have chosen to continue to fight but find not so “compliant” means to keep their businesses running. And while from a staunch compliance position the option of creativity is frowned upon, the de-risking and de-marketing banking practices are feeding this creativity. This is creating an environment of pushing businesses to utilise “underground” or “covert “practices in order to process the volume of transactional money flow. The money flow is the most important aspect of these businesses, for it is the money supply and demand business model that keeps their businesses afloat, provides the needed service and becomes a important factor in our global economic growth.

Here in Canada, the Money Service Business industry, including all those that fall under this industry sector, formed an association; The Canadian MSB Association. The mandate of the Canadian MSB Association, is to bring about structure, compliance adherence, provide training and information conferences. In turn the hope is it will change the opinions of the industry’s banking partners and regulators. The association wants them to know that their concerns are being taken seriously and the industry is prepared to hold itself accountable to doing business within a regulatory frame-work.

Globally there are many other association like ours here in Canada. When the news of banks taking steps to de-risk and de-market our fellow colleagues internationally, the Canadian MSB Association along with our fellow colleagues and our fellow associations took action., As there is strength in numbers we joined forces. We opened discussions, we sent letters and our voice was heard in front of the Deputy Minister of Finance here in Canada. Eventually the World Bank got wind of the issue and the call to action began.

Do each and every one of you who are either directly or indirectly affected by this global de-risking and de-marketing issue understand what we collectively were able to do? Let me repeat! We joined forces with our fellow colleagues, our fellow industry associations, we opened discussions, we sent letters and we had our voices heard and then….. and THEN…. The WORLD BANK took note!

Let that fact sink in for a moment and appreciate the value statement this makes. When a united force comes together to bring about change, change can happen but the unification of our industry was only half of the required action needed to bring about change. The battle was only half won. This collective action we took cannot stand still. The World Bank took note, and then they took action. They created a Survey and asked us to respond to the Survey in order to assist them in bringing the proof required of our experiences, of the unfair de-risking and de-marketing practices the global banks are taking.

In some ways the World Bank can be considered a mediator. They bring to the global banking and finance decision makers the world’s economic concerns. They hold regular annual meetings where they discuss and make decisions on global concerns, including the world economic outlook, poverty eradication, economic development and aid effectiveness. The mandate of the World Bank is to end extreme poverty by decreasing the percentage of people living on less than $1.25 a day to no more than 3%. Additionally, they promote shared prosperity by fostering the income growth of the bottom 40% for every country.

These underprivileged individuals along with third world countries and under-banked countries rely on the global presence of Money Service Businesses, Remittance Services, E-Money, Money Transmitters and Third Party Payment Providers as a means to receive money from family and to buy goods and services they otherwise would not have access to. This industry fulfills a cost efficient need that the big banks simply cannot fulfill.

Finally our voices were heard. We are fighting for our right to exist along side the big global banks, our right to a livelihood, to provide services to those countries and individuals in need and we are part of the cause and effect solution.

The World Bank took us seriously. They launched a survey in order to collect the needed data to provide to World Government Officials, decision makers of the global financial ecosystem. The data is needed to provide accurate statistical information so a complete picture can be seen. Only once the data is collected, reviewed and analyzed can the confirmation of our struggles, the unfair treatment and the misunderstood business practices be confirmed.

The World Bank reached out to those of us they saw as activists for the industry or those individuals that were directly or indirectly involved in changing the perception of the industry. The World Bank was looking for our assistance in communicating the Survey to the Industry. Collectively many of us used whatever means we could to communicate to all of you, the news of the Survey and how to access the Survey. Using email blasts, discussion groups, training webinars, committee conference calls, tweets and throughout most social media networks, we worked to spread the word of the World Bank Survey to industry counterparts, colleagues and fellow associations.

However the feedback from the World Bank is that the response from the industry was pitiful. Too few industry members responded and the data is incomplete. The common whisperings heard as to why members of this industry did not respond to the survey? It is believed that it is our position on not wanting to share information, our wanting to remain anonymous, and our lack of trust of the process.

In hearing this feedback from the World Bank it made me think of the boy who called Wolf.

Have we as an industry cried Wolf? Did we bring the decision makers and law-makers to our doorstep ready to listen, ready to show a willingness to work with our Industry and understand our business only to not follow through with the needed information that a “wolf” actually exists? By responding to the survey it would provide us the opportunity to show them the steps we have taken collectively as an industry, to unite and create a culture of compliance with the objective to not only blindly follow the rules but to safeguard our financial banking systems. This kind of opportunity does not come around often to an industry in need. We missed their first attempt to help us by collecting the information needed when requested. This kind of opportunity does not come around a second time so as the fable of the boy who cried wolf goes; what are the chances that we will be provided a second let alone third opportunity to be heard and to bring about change. We have our second opportunity to be heard as they have extended the deadline for the collection of this information. In the fable of the boy that cried wolf, help is attempted twice before his cries are no longer answered. Let’s use this opportunity or stop-crying wolf!

The de-risking and de-marketing issues are real. They are happening. You know it, I know it and all of us in this industry know it. It is unfortunate that the bureaucratic way to change is to have to prove ones case. Nothing can ever be hearsay. We must prove our case not just give lip service. Lip service is easy and holds little accountability and responsibility. Taking action means seeing the process through to the end and being accountable, and being responsible. The game changers are ready to be engaged. Having your voice heard is an incredible accomplishment – and a shame to let it be wasted and more so for all of us who desperately need change to happen. I am hopeful that it is not too late; the survey is still available online at : https://remittanceprices.worldbank.org/en/survey-on-de-risking

Please lets not simply cry wolf and take no further action. This initiative is a collective one and we need each and every one of you to act. The next step is to provide the information needed to guide those that can help us, to what needs to happen next for this industry to move forward!