ISO 20022 The Challenges and Opportunities for APAC's Financial Institutions

 
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ISO 20022 The Challenges and Opportunities for APAC's Financial Institutions
ISO 20022
The Challenges and
Opportunities for APAC’s
Financial Institutions
OVERVIEW
• The introduction of ISO 20022, an international messaging
  standard for financial institutions, represents a seismic shift in
  international payments.

• Financial systems, financial institutions and other players
  across the globe are working to become compliant with ISO
  20022, which aims to replace existing proprietary formats,
  and which contains much richer data.

• While in most cases, compliance is a regulatory/scheme-
  driven big-bang requirement, the global SWIFT migration
  provides a four-year window for migration by 2025.

• However, failure to comply earlier in the window could
  ultimately see non-compliant financial institutions shut out of
  international payments due to the risks they impose on those
  that are compliant.

• There are two ways to become compliant: use a central
  translation service or develop a native ISO 20022 payment-
  processing ability.

• Using a central solution can be useful - particularly for smaller
  financial institutions. However, in most cases this will prove
  only a stop-gap arrangement, and it does have downsides.
  We recommend that the majority develop a native ISO 20022
  processing capability.

• The latter approach brings a range of benefits: it allows
  financial institutions to maintain data as a strategic asset and
  use it for a wide range of value-added solutions, including
  providing customers with targeted products and services;
  and it gives financial institutions a better chance of complying
  with future regulatory requirements in areas such as anti-
  money laundering.

• Data is the new oil, and developing a native ISO 20022
  capability will allow the financial institution to retain rich data
  about each payment at a time when such data is becoming
  more important than the payment itself.

• Developing an appropriate compliance strategy requires
  board-level engagement, because ISO 20022 cuts across a
  range of operational and infrastructural areas.

2   ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
01.
ISO 20022 UNDERWAY IN APAC
Work on implementing ISO 20022 is well                      Systems in India and China are already
underway in the APAC region (see Figures                    compliant, while work is underway in Hong
1 and 2). Japan’s central bank, for example,                Kong (its CHATS system will migrate from
has redesigned its real-time inter-banking                  the current MT format to ISO 20022 by the
system to ensure it is ISO 20022 compliant.                 end of 20221 ) as well as in Malaysia, which
Both its counterpart in Australia and the                   will implement ISO 20022 for real-time gross
Australian Payments Network (the industry’s                 settlements (RTGS) by 2020.2
self-regulatory body) aim to adopt ISO 20022
by 2024. Singapore’s central bank has begun
planning, with migration scheduled for 2021.

Figure 1: ISO 20022 is already here

ISO 20022 IS NOT COMING.
IT’S ALREADY HERE.

ACH/                        REAL-TIME          HIGH-VALUE           CROSS-             SECURITIES,
BULK                        INSTANT            PAYMENTS -           BORDER             TRADE
PAYMENTS                    PAYMENTS           RTGS                 PAYMENTS           FINANCE, FX

• SEPA (Eurozone)           • Singapore FAST   • Japan BOJNET       • SWIFT MT to MX   • T2S (Eurozone)
• Singapore FAST            • Australia NPP    • India NG-RTGS                         • FX
  bulk                      • Malaysia RPP     • Brunei BN-RTGS     From 2021:         • Trade Finance
• + many others                                                     All SWIFT
                            • Hong Kong FP     • China
                                                                    cross-border and
                            • US FED RTP         CIPS/CNAPS
                                                                    correspondent
                            • UK Faster        Upcoming:            banking
                              Payments         • Singapore MEPS+    participants
                            • SEPA SCT         • Malaysia RENTAS
                            • India IMPS       • Phillippines
                            • + many others      PhilPaSS
                                               • Thailand BAHTNET
                                               • + many others

Source: Accenture and FIS

3     ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
Figure 2: Where ISO 20022 has been adopted, or soon will be

ISO 20022 ADOPTION BY RTGS SYSTEMS

    Live with ISO 20022
    Under review/Planned
    Under review/Planned

Colombia               Switzerland     Jordan           India             Kosovo          Bangladesh
2007                   SIC, 2016       JO-RTGS, 2015    NG-RTGS, 2013     IPS-RTGS        RTGS, 2015
Brunei                 Japan           China            Malaysia          Singapore       Myanmar
BN-RTGS, 2015          BOJ-NET, 2015   CIPS/CNAPS, 2015 RENTAS, 2020      MEPS+, 2021     CBM-NET, TBD
Canada                 U.S.            U.K.             E.U.              Thailand        South Korea
LYNX, 2022             Fedwire/        CHAPS, 2022      Target2, Euro1,   BAHTNET, 2020   BOK-Wire+, TBD
                       CHAPS, 2022                      Step1, 2021
Vietnam                South Africa    Philippines      Australia         Hong Kong
IBPS RTGS, 2020        SAMOS, TBD      PhilPaSS, 2021   RITS, 2024        CHATS, 2022
Indonesia              Laos
BI-TGS                 LA-RTGS

Source: Accenture and FIS

Along with the in-country clearing systems              Finally, SWIFT – the network that supports
and the array of RTGS systems, many low-value           the majority of cross-border transactions4
real-time schemes in APAC are also either               – will migrate all of its payments and cash
ISO 20022 compliant or working to become                reporting MT formats to ISO 20022
so. Thailand’s PromptPay is one such system.            supported MX formats over the four-year
                                                        period to November 2025.
There is much more to come. Within the
10-member ASEAN group, for example,                     We expect that the progression of ISO
adopting global standards like ISO 20022 is             20022 compliance in APAC will follow
an explicit and key measure under the body’s            the Three Waves model outlined in
ASEAN 2025 Vision.3                                     Figure 3, with 2025 being the deadline
                                                        by which financial institutions will need
                                                        to have made their transition.

4     ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
Financial institutions in APAC that aren’t                Complying with ISO 20022 for payments
ready and that haven’t planned to migrate                 is a mandatory requirement for financial
in time could find themselves at a serious                institutions operating in countries whose
disadvantage. In the worst-case scenario they             domestic schemes require compliance.
might be excluded from payments networks.                 But even for those in countries that don’t,
Financial institutions that try to minimise               complying brings a range of commercial
their ISO 20022 compliance are likely to face             benefits if done early and properly. By
higher costs due to lower straight-through-               ‘properly’, we mean that most should adopt
processing (STP) rates, as well as the loss of            full native compliance, as we shall see shortly.
corporate customers because they cannot
offer a seamless host-to-host experience.

They could also potentially incur penalties
because they cannot track sanctions
requirements or assess anti-money laundering
(AML) and counter-financing of terrorism
(CFT) counterparty risks with as much
accuracy as those financial institutions that
have fully committed to the ISO 20022
standard. Moreover, bad actors will see these
financial institutions as weak links and, as
such, they might attract unwanted attention.

Figure 3: How ISO 20022 compliance is evolving in APAC

THE THREE WAVES OF ISO 20022
                                                                  SWIFT cross-border to
                                                                  simplify and streamline
                                                                  cross border payments
                                                                  by moving to ISO 20022
                                          High-value payments
                                          move to ISO 20022 to
                                          provide a superior,
                                          data-rich RTGS system

             Real-time payments using                                         3
             ISO 20022 introduced to
             provide an alternative                 2
             consumer payment rail
             (plus bulk)

                              1

             2018           2019   2020      2021       2022      2023     2024      2025

Source: Accenture and FIS

5     ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
6   ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
02.
A REVOLUTION IN MESSAGING
It is worth delving a little deeper into ISO        The good news is that complying with ISO
20022 – what it is and what it provides. First,     20022 will bring numerous benefits (see
it is an international standard that lays out       Figure 4). Firstly, the messaging architecture
a platform to ensure consistent messaging           has thousands of fields, and structured
globally for data flows between financial           placeholders, which makes it far more data-
institutions. Second it provides a common           rich. In a world where data is the new oil,
language for five financial business domains:       this will allow financial institutions to apply
payments, securities, trade services, cards         analytics to leverage that richness and create
and foreign exchange.                               more compelling offerings for their customers.

ISO 20022’s introduction represents a seismic       Complying, as some financial institutions have
shift in international payments, with more          done, brings other advantages:
than 200 initiatives in over 70 countries
either live, being rolled out, planned or           • Improved automation and lower STP costs.
under discussion.5 Provided implementation          • The ability to meet consumers’ demands for
deadlines are met, ISO 20022 “will dominate           new services, as well as their expectations of
high-value payments” by 2023, SWIFT has               real-time, all-the-time payments.
said, and will account for 79 percent by
volume and 87 percent by value of those             • An increased ability to meet compliance
transactions globally.6                               requirements in areas such as know your
                                                      customer (KYC), AML and CFT.
One key reason that a new messaging
standard is necessary is because SWIFT’s            • Improving the efficiency of payment
40-year-old MT standard is no longer suitable.        processing and inter-operability among High
Its limited data-carrying capabilities are the        Value Payment Systems (HVPS).8
product of a time when bandwidth and storage        • Superior tracking to provide a better service.
were expensive, while regulatory requirements
mean much more data is now needed to                Given that ISO 20022 is already in motion,
comply fully with AML and CFT laws.7                financial institutions that have yet to start
                                                    preparing should do so now. Failing to
                                                    act carries significant, and possibly
                                                    existential, risks.

Figure 4: The benefits of ISO 20022

MOTIVATIONS FOR INTRODUCING ISO 20022

    Consumer                Automation      End-to-end          Regulatory          Data, data, data
expectations of              and STP to       payment           demand for
    Real-Time,              reduce cost     tracking for       better tracing
All-the-Time and                           better service    and transparency
demand for new
     services
Source: Accenture and FIS

7     ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
03.
PREPARING FOR ISO 20022:
PATHWAYS TO SUCCESS
The upshot, then, is that financial institutions      Central translation
in APAC must migrate. When doing so, they
should bear in mind that migration goes               There are several types of central translation
far beyond payments processing. On the                options in which the incoming ISO 20022
operational side it will affect KYC systems,          compliant message in MX format is translated
liquidity management and electronic banking,          to the MT format, either through an in-flight
among others, and will require areas such             translation or via a cloud-exposed API. That
as treasury, securities and trade finance to          makes rapid compliance possible. However,
process and apply the information involved.9          it has a number of downsides that in effect
                                                      make this a stop-gap solution for most financial
On the infrastructure side, complying with ISO        institutions. Those downsides include:
20022 means handling significantly more data
than before. That means systems, databases            • An increased risk of data-loss due to the
and other aspects must be able to process far           truncation of rich data messaging into
larger volumes of data – and to do so fast - to         abbreviated versions. Truncation creates
ensure not only that real-time payments can be          work if financial institutions need to
dealt with, but also that the financial institution     compare truncated MT messages with the
stays on top of requirements such as fraud              MX original.
prevention, compliance checks and intraday
                                                      • Audit-related issues such as hampered
liquidity management.
                                                        traceability of payments.
This broad scope in both operational and              • Reduced ability to carry out compliance
infrastructure requirements means ISO 20022             screening correctly – heightening
requires board-level commitment.                        compliance risks.
Financial institutions that have yet to start will    • A reduction in STP rates.
find there are two options open to them in
                                                      • The lack of rich data means financial
enabling ISO 20022:
                                                        institutions using this approach will not
• Using a central translation on the cloud,             be able to exploit fully that information to
  such as that offered by SWIFT.                        design and target products and services for
                                                        customers, which means they will miss out
• Implementing a native ISO 20022 payment-              on future revenue streams.
  processing solution locally.
                                                      Using a central translation service, then,
                                                      can prove a useful head-start for smaller
                                                      financial institutions that are fully aware
                                                      of those downsides. However, it is not
                                                      recommended over the longer term or for
                                                      larger financial institutions looking to take
                                                      a more strategic view. Instead, they would
                                                      be better off examining the second option:
                                                      developing a native ISO 20022 payment-
                                                      processing capability.

8    ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
Native ISO 20022                                 Once the impact is understood, financial
                                                 institutions can undertake a varied approach,
payment processing                               either enabling all applications natively for ISO
This is a permanent solution that addresses      20022 compatibility or using middleware.
the problem holistically and includes
                                                 An application-by-application replacement
consideration of peripheral systems such as
                                                 will take a considerable amount of time and
screening systems, local reporting, regulatory
                                                 effort and, in the end, one might end up
reporting, archiving and so forth.
                                                 replacing legacy siloed applications with new
So, how can financial institutions go about      siloed applications. A middleware option does
developing a native ISO 20022 processing         not fully bring out the benefits of native ISO
capability? And what options are available?      processing and, if not carefully planned, might
                                                 still end up with data truncation.
The first step is to do a thorough impact
analysis, which can be carried out using a       Our recommendation is that financial
simple framework of questions:                   institutions future-proof their architecture by
                                                 adopting a platform approach. Under such an
1. How many applications are affected,           approach, there is no truncation of messages.
   including peripheral ones?                    Instead, messages sent in ISO 20022 are
                                                 received, read and stored in that mode, which
2. How many messages within each
                                                 enables the financial institution to reap all of
   application are affected?
                                                 the benefits listed earlier. This makes native
3. What is the migration deadline?               ISO 20022 processing a permanent solution
                                                 that addresses the problem holistically.
4. Can the application support the
   ISO 20022 data model?

5. Does the application require message
   transformation before processing?

6. Does the application support multi-byte
   characters in the event that specific local
   language support is required?

7. Are there any performance considerations
   or impacts?

8. What level of ISO 20022 integration
   do my corporate customers expect,
   including direct integration with ERP
   and accounting systems?

9   ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
CASE STUDY
Preparing for ISO 20022
FIS and Accenture worked with a large                  The core component in the payments
European bank to help it undertake a                   transformation journey was FIS’s Open
major and successful payments system                   Payments Framework (OPF), which solved
transformation as part of an enterprise-wide           for SCT compliance. Additionally, the bank
technology overhaul. The aim was to run on             benefited from a Payment Simplification and
one global payment engine, in preparation              Transformation Program, resulting in it having
for ISO 20022 migration. That meant solving            fewer systems to manage (down from 49 to 10).
an array of challenges, the first of which was         And it now boasts a consistent product offering
to ensure the integrity of 700 integration             across the countries in which it operates.
points with 250 systems, and to do so with
49 payment systems across several countries.           On the ISO 20022 side, these changes
                                                       mean the bank now enjoys:
A second was to ensure that the bank was
compliant with the requirements of SEPA Credit         • Full ISO 20022 processing capability, with
Transfer (SCT) – the rules that underpin funds           no data truncation.
transfers between EU financial institutions –          • Support for multiple ISO 20022 payment
while a third was to incorporate a wide range            types on the same OPF platform, including
of local product variants and processes.                 SCT Inst and SCT Batch. Support for
                                                         TARGET2, the Eurozone’s RTGS system, and
                                                         the Nordic’s P27 payments platform is also
                                                         planned.

BENEFITS OF THE                                        • Migration to ISO 20022 for SWIFT MX is now
PAYMENTS PROGRAM                                         simply a matter of configuration.

                                                       Additional benefits included infrastructure
                            1   2                      harmonisation that reduced the necessary
           Payment                                     knowledge-base to operate and run;
           System               Infrastructure         payments-system stability improvements;
           Simplification       Harmonization          a reduction of production incidents; easier
                 4                                 3   payment-processing monitoring capabilities;
     Payment                                           and a consistently high STP rate.
     System
     Stability       Payment Processing
     Improve-        Monitoring Capabilities           It is worth reiterating that full ISO 20022
     ment                                              transformation is for financial institutions
                                                       that are forward-thinking and of a certain
                                    5              6
                                                       size. For smaller players with lower volumes
             Migration to ISO           Maintain
             20022 for SWIFT            High           and less capacity to implement a platform
             is just a format           STP            solution, it would still be useful to consider
             change                                    the cloud translation solutions - assuming
                                                       they can accommodate manual processing,
                                                       and manage and mitigate operational and
Source: Accenture and FIS                              compliance risks carefully.

10    ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
04.
THE TIME TO ACT IS NOW
With the clock ticking on ISO 20022               Whatever the timescale, financial institutions
implementation across APAC, financial             must act now to ensure they are ISO 20022
institutions should start planning their          compliant. And they must do so in the
approach now before it’s too late.                knowledge that using a central translation
                                                  solution does not manage or mitigate the risks;
That raises one final question: How long          it simply moves them to operations at the cost
does it take to become ISO 20022 compliant?       of STP and manual intervention.
Financial institutions looking to undertake
a comprehensive enterprise transformation         A native ISO 20022 processing solution, on
programme should expect that this will take       the other hand, both manages and mitigates
several years, with the timescale dependent       the risk by eliminating the underlying problem,
upon a few crucial factors: the number            and turns the developed native-processing
of countries the financial institution has a      capability into a competitive advantage. For
presence in; the payment schemes that are         larger financial institutions and for those with
operating in each of those countries (usually     an eye to the longer-term, it is the better
three or four); and the effect migration will     strategic choice.
have on peripheral factors such as risk,
treasury, reporting and data storage,
many of which will need to be upgraded.

11   ISO 20022 – The Challenges and Opportunities for APAC’s Financial Institutions
References                                            About Accenture
1. Unlock the Potential: Stand Out with ISO           Accenture is a leading global professional
   20022, FIS (2019).                                 services company, providing a broad range of
   See: https://empower1.fisglobal.com/               services and solutions in strategy, consulting,
   Stand-Out-with-ISO-20022.html                      digital, technology and operations. Combining
                                                      unmatched experience and specialised skills
2. Ultimate guide to ISO 20022 migration,
                                                      across more than 40 industries and all business
   Deutsche Bank (2019).
                                                      functions—underpinned by the world’s largest
   See: https://cib.db.com/docs_new/
                                                      delivery network—Accenture works at the
   UltimateGuide-EN-Top.pdf
                                                      intersection of business and technology to help
3. ASEAN Economic Community Blueprint                 clients improve their performance and create
   2025, ASEAN Secretariat (2015).                    sustainable value for their stakeholders. With
   See: https://www.asean.org/                        482,000 people serving clients in more than
   storage/2016/03/AECBP_2025r_FINAL.pdf              120 countries, Accenture drives innovation to
                                                      improve the way the world works and lives.
4. Accelerated ISO 20022 Adoption Promises            Visit us at www.accenture.com.
   Easier Domestic and Cross-Border
   Transactions, American Express (undated):          About FIS
   https://www.americanexpress.com/us/
   foreign-exchange/articles/iso20022-                FIS is a leading provider of technology
   adoption-accelerated-cross-border-                 solutions for merchants, banks and capital
   transactions/                                      markets firms globally. Our 55,000 people are
                                                      dedicated to advancing the way world pays,
5. Introduction to ISO 20022, Accenture.
                                                      banks and invests by applying our scale, deep
6. SWIFT ISO 20022 Migration Consultation             expertise and data-driven insights. We help our
   Study, SWIFT (April 23, 2018).                     clients use technology in innovative ways to
   See: www.swift.com/resource/iso-20022-             solve business-critical challenges and deliver
   migration-study                                    superior experiences for their customers.
                                                      Visit us at www.fisglobal.com.
7. Ibid.

8. Ultimate guide to ISO 20022 migration,             Authors
   Deutsche Bank, op cit.                             Anand Bindumadhavan
9. Ibid.                                              Principal Director, Accenture
                                                      Stephen Peters
                                                      Director, FIS

                                                      Acknowledgements
                                                      Joel Pereira
                                                      Management Consultant, Accenture
                                                      Valerie Lee
                                                      Analyst, Accenture
                                                      Elena Whisler
                                                      Global Head of Product Mgmt, FIS
                                                      Guy Moons
                                                      Head of Solution Consulting, FIS
                                                      Bert de Munter
                                                      Product Manager HVP, FIS

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