Citi Perspectives | Autumn 2016 Citi PERSPECTIVES · Citi PERSPECTIVES Citi Perspectives | Autumn...
Transcript of Citi Perspectives | Autumn 2016 Citi PERSPECTIVES · Citi PERSPECTIVES Citi Perspectives | Autumn...
Citi PERSPECTIVES
Citi Perspectives | Autumn 2016
04 Perspectives for 2017: creating optionalityA look ahead to 2017 as treasury teams plan for new challenges
14 Brexit: the effect on corporatesAn assessment on the potential impact on different corporate sectors
Cybersecurity: the impact to the financial supply chainAn overview of the effect of cybercrime on the business and banking community
36
Treasury and Trade Solutions transactionservices.citi.com
© 2016 Citibank, N.A. All rights reserved. Citi and Arc Design, CitiConnect and CitiDirect are trademarks and service marks of Citigroup Inc. or its affiliates, used and registered throughout the world. The information and materials contained in these pages, and the terms, conditions, and descriptions that appear, are subject to change. The information contained in these pages is not intended as legal or tax advice and we advise our readers to contact their own advisers. Not all products and services are available in all geographic areas. Your eligibility for particular products and services is subject to final determination by Citi and/or its affiliates. Any unauthorized use, duplication or disclosure is prohibited by law and may result in prosecution. Citibank, N.A. is incorporated with limited liability under the National Bank Act of the U.S.A. and has its head office at 399 Park Avenue, New York, NY 10043, U.S.A. Citibank, N.A. London branch is registered in the UK at Citigroup Centre, Canada Square, Canary Wharf, London E14 5LB, under No. BR001018, and is authorized and regulated by the Financial Services Authority. VAT No. GB 429 6256 29. Ultimately owned by Citi Inc., New York, U.S.A.
These materials are provided for educational and illustrative purposes only and not as a solicitation by Citi for any particular product or service. Furthermore, although the information contained herein is believed to be reliable, it does not constitute legal, investment or accounting advice and Citi makes no representation or warranty as to the accuracy or completeness of any information contained herein or otherwise provided by it.
GRA27448 09/16
Citi Perspectives | 1
WelcomeNaveed Sultan Michael Guralnick
Perspectives for 2017: creating optionalityRon Chakravati
Shared service centers: from operational efficiency to value creation Swati Mitra
02
56
04
Regional treasury centers come of age in Latin AmericaGabriel Kirestian
Navigating regulations, rates and risk in Asia: three key trendsNishami Dharmaratne Deborah Mur
Taking onboarding into the 21st centurySabine McIntosh Rob Schlaff
08
20
24
42
32
48
Commodity prices: the impact on trade financeKris Van Broekhoven
Corporate split or spinoff: finance in the hot seat Jeffrey A Miller Kelvin Ang Ambrish Bansal
Is cash still king?Ron Tauscher
52Global tax initiatives: the evolving regulatory environmentDan Stern
Cybersecurity: the impact to the financial supply chainRaj Shenoy
36
14 Brexit: the effect on corporatesSteve Elms John Murray Peter Cunningham Roberto Di Stefano James Lee
2 | Treasury and Trade Solutions
WelcomeWelcome to the second edition of 2016’s Treasury and Trade Solutions’ Citi Perspectives. Throughout 2016, we have seen and continue to see new challenges across all industries and geographies, challenges that we are addressing to support our clients’ commercial growth agendas. These range from uneven macroeconomic dynamics to concerns related to increasingly sophisticated cybersecurity risks, currency volatility, regulatory compliance, and changes in the banking landscape. Together, these challenges have made the corporate treasury team’s job all the more complex, yet all the more important.
Naveed SultanGlobal Head, Treasury and Trade Solutions, Citi
Michael GuralnickGlobal Head, Corporate and Public Sector Sales, and Global Marketing, Treasury and Trade Solutions, Citi
02
Citi Perspectives | 3
As businesses continue to look for
transformational growth opportunities,
treasury teams are looking for advice
and insights leading to the design of
value-added solutions that reduce
costs, lower risks, and optimize
operating models to support enterprise
aspirations and strategies. Companies
are leveraging new e-commerce
channels for growth, and these new
channels have become catalysts
for financial services innovation, as
corporate and consumer payment
and collection channels intersect and
require new and evolved trading and
treasury models.
In this edition of Citi Perspectives, we
take a closer look at some of these
key corporate challenges along with
the latest trends that are having an
impact on treasury activities globally.
Among the topics we cover is the
understanding of the increasingly
complex regulatory, rate, and risk
landscape in Asia. In “Navigating
Regulations, Rates and Risk in
Asia: Three Key Trends,” we examine
banking regulatory and interest-rate
changes taking place in the Asia-
Pacific region, and how diverse legal
frameworks, economic systems,
commercial languages, and banking
infrastructures are presenting unique
challenges and opportunities for
corporate treasurers.
Another headline-grabbing story is
the UK EU membership referendum.
We look at the potential implications
of Britain’s pending exit from the
EU as it pertains to several different
industries, in particular aviation
and healthcare. We delve into how
this is likely to affect sales, research
and development, regulations, and
treasury and finance planning.
As news of cyberattacks seemingly
dominate the headlines on a daily
basis, corporates and banks are
constantly looking to stay out of the
headlines. In “Cybersecurity: The
Impact to the Financial Supply Chain,”
our industry experts explore the
effect of cybercrime on the business
and banking community and, more
specifically, how treasury and the
financial supply chain is vulnerable.
We share the latest best practices on
proactively improving internal fraud-
prevention and post-attack mitigation
within the financial center.
As we are seeing a growing trend
towards centralization via Shared
Service Centers, we include an article
on how many of these centers are
increasingly focused not only on
operational efficiency but also on
value creation.
Through the articles in this edition
of Citi Perspectives, we hope you will
gain critical insights into issues that
concern you and your business. We
stand ready to work with your teams
to design optimal solutions to address
these business challenges and achieve
your strategic goals.
As always, we would be delighted to
hear your thoughts and views on any
of the issues raised by the innovative
thinking of our thought-leaders.
Citi is ready to design optimal solutions to address business challenges and your strategic goals.
Perspectives for 2017: creating optionality
4 | Treasury and Trade Solutions
04
As corporate treasurers look ahead to 2017, the global outlook remains mixed. Gradually improving economic growth provides positive momentum.
Citi Perspectives | 5
Ron ChakravatiGlobal Head, Treasury Advisory and Solutions, Treasury and Trade Solutions, Citi
Macroeconomics: sluggish, if steady Citi projects global GDP growth to be slightly higher in
2017, at 2.7%, as growth picks up in emerging markets and
the US. With inflation low, monetary policies of most major
central banks are likely to remain accommodative into
2017, with the US an outlier. Despite an outlook for rising
US interest rates, on FX rates, Citi expects the rising dollar
cycle to be coming to an end, with US dollar depreciation
against G10 currencies of 3% over six to 12 months.
Uncertainties in the macroeconomic outlook, geopolitical trends, financial system regulation, and moves in tax compliance create new challenges for treasury teams in planning forward. In our client engagements, Citi’s Treasury Advisory Group finds corporate treasury teams actively considering scenarios and assessing actions.
6 | Treasury and Trade Solutions
Financial system regulations: change is a constant
Geopolitics: downside risksThe situation remains fluid — from the
continuing conflict and displacement
of people in the Middle East to the
changing geopolitics of energy and
new security developments in the
South China Sea. Brexit and the US
election cycle (regardless of who
becomes president) are symptoms
of the increase in uncertainty in
even major markets. In Citi’s view,
geopolitical instability will be a feature
of the landscape for the foreseeable
future across emerging markets and
industrialized economies, creating
downside risks for the overall
growth outlook.
Treasury teams are aware, painfully perhaps, that know-
your-customer (KYC) and anti-money-laundering (AML)
regulations have placed tighter controls on bank account
and transaction management. Most are also broadly aware
that Basel III-related regulation has reshaped banks’ capital
and liquidity management. What is not so well appreciated is
that changes continue to ripple through the financial system.
For example, recent Basel Committee proposals on bank
leverage ratios and on capital assessment for loans to large
corporates may have impacts on notional pooling, a popular
cash management technique, and on the cost of bank credit
lines. Any impacts will depend on the finalized rules and on
what national regulators implement. The larger point is that
change is becoming a constant. Treasury teams need to
maintain an ongoing dialogue with relationship partners on
what is coming and the implications for relationships.
Macroeconomics
Challenges
Tax Geopolitics
Regulation
Citi Perspectives | 7
The view ahead: creating optionality
Tax: keeping treasury busyThe US Treasury’s recent proposals under Section 385 have
caught the attention of US- and foreign-based multinationals
alike. The goal is to limit “earnings-stripping” through the use
of cross-border debt that reduced US income taxes, but it has
consequences that may have been unintended. Depending
on the final rules, companies may have to change how they
manage day-to-day internal funding and treasury operations.
Many widely used cash management techniques, from cash
pooling to in-house banking, may need to be modified.
Meanwhile, the OECD-led Base Erosion and Profit Shifting
(BEPS) initiative is transitioning into implementation in many
countries. Here, the chief goals are to improve cohesion of tax
rules across countries, while ensuring greater transparency
and compliance. As a consequence, some companies are
changing trading models that drive where taxable income
is generated. Since trading model changes may affect the
company’s cash and funding needs, both in amount and where
these arise, treasury teams will be kept busy.
Treasurers may sometimes feel as if
new challenges never cease to arrive.
What is clear is they cannot lessen the
drive to centralize treasury operations
and automate processes. Doing so
equips treasury teams to shift away
from tactical or operational mode,
creating capacity to manage the
unexpected and to bring treasury’s
unique perspectives to the business
for greater value.
Shared service centers: from operational efficiency to value creation
08
8 | Treasury and Trade Solutions
Citi Perspectives | 9
As companies deal with the challenges of globalization, economic uncertainty, new regulations, rapidly changing technology, and a volatile business environment, many are searching for ways to reduce cost and complexity in their operating model.
In the interests of making the
most of investing in technology,
simplifying operating models, and
driving corporate governance, more
and more corporates are setting
up shared service centers (SSCs).
SSCs can be used to automate and
standardize processes, whether at
regional or global levels, and improve
the efficiency of many back-office
functions, e.g. payment processing,
accounts receivable, and financial
reporting. In doing so, companies
often find that they can improve
working capital and optimize cashflow,
support growth with increased
productivity, and position themselves
to more effectively manage risks.
By centralizing such functions,
companies also avoid the difficulties
of having to replicate the necessary
infrastructure and skills in each
market as they grow organically, or
through mergers and acquisitions.
While the success criteria and key
performance indicators for SSCs
remain cost-savings driven, one of
the key characteristics that is defining
the evolution of these centers is the
recognition of value add and service
enhancement that they can bring
with data analytics, technology-led
solutions, and risk management being
key contributing factors.
Given our extensive SSC client
base at Citi of more than 1,200
clients, we increasingly find that
SSCs are becoming more integral to
organization-wide strategic initiatives
such as deployment of technology,
procurement initiatives, mergers,
acquisitions, and spinoffs, and growth
in emerging markets. We have not
seen significant shifts in the location
choices for SSCs, with Asia, Central
and Eastern Europe, and Central
America remaining highly attractive,
Swati Mitra Global Sales Leader, Emerging Market Corporate Clients, Treasury and Trade Solutions, Citi
10 | Treasury and Trade Solutions
and North America and Western
Europe still seeing some hubs in
selected sectors.
Geographic expansion and changes
in organizational constructs are
widening the scope of activities
for SSCs. Many have evolved from
low-cost, high-volume processing
hubs to centers of excellence, and
ultimately they are moving towards
global organizations, often referred to
as global business services. By bringing
together operational activities across
multiple functions and regions under
a single organizational framework,
companies are able to achieve end-to-
end ownership of significant functional
process flows that are supported
by strong governance models with
strategic business partners.
As a result of their broader role,
reporting lines are also changing. A
financial SSC may have reported to
the treasurer or CFO in the past, but
today we are seeing the responsibility
increasingly shift to the global head of
supply chain, the head of procurement
or the chief operating officer. These
may have different objectives from
those of the CFO or treasurer, which
is further fuelling an expansion in
responsibility, e.g. procurement.
Centralizing procurement creates
greater purchasing power and
economies of scale, but building
synergies between procurement
and finance also offers considerable
advantages in areas such as working
capital management using techniques
such as supply chain financing. It is
also becoming increasingly important
for SSCs to align with finance and
treasury on roles and responsibilities
and performance metrics.
Many of Citi’s SSC clients are
adding functions, expanding to new
geographies, and pushing for further
efficiencies in their processes to bring
their SSCs to the next level. Areas
such as reconciliation, reporting
and analysis, travel and expense,
data management, and supporting
e-commerce platforms and flows are
among the wider range of functions
being centralized to drive incremental
value from a purchase-to-pay and
order-to-cash perspective.
Technology is playing an increasingly
important role in SSCs driving additional
value. With the evolution of cloud-
based technology, mobile, new industry
standards for file formats, and access to
innovative data analytical and diagnostic
tools from banks like Citi, SSCs can
play a crucial role in identifying new
areas for improvement, e.g. optimizing
cross-currency payment flows, lowering
payment processing costs by switching
from paper to electronic, implementing
card-based solutions, and improving
days sales outstanding by implementing
automated receivables reconciliation
solutions. As cyberattacks become a
growing reality, SSCs can also lead
the way in partnering with banks like
Citi to implement solutions such as
host-to-host connectivity, mobile
alerts, digital signatures and workflow
tools that mitigate cyberthreats and
cyberfraud risks.
Many of Citi’s SSC clients are adding functions, expanding to new geographies, and pushing for further efficiencies in their processes.
Citi Perspectives | 11
In some industries, e.g.
pharmaceuticals and technology,
SSCs are pursuing offshoring and
outsourcing, driving increased
automation and pushing an agenda
of process streamlining. Such
organizations view the savings from
wage arbitrage as unsustainable and
prefer to move to a variable cost
model. There are pros and cons to
this approach but we have seen some
companies move in this direction.
A key factor in delivering best-in-class
SSC operations is close collaboration
with an experienced banking
partner. This is particularly true for
organizations that are expanding
their SSC operations, and that
need guidance on different banking
regulations in each market and
advice on the optimal roadmap that
will help them progress given their
dependencies on technology, people,
and processes. With our geographic
footprint at Citi, which includes access
to clearing systems in more than
100 countries, and our large client
base of 1,200 SSCs worldwide, we are
focused on providing advisory, insight,
and solutions through webinars,
workshops, and SSC forums in each
region, allowing our clients to share
their experiences and discuss best
practices. While there are clear
challenges in the journey to and
ongoing contribution from SSCs, the
tangible and intangible rewards are
often significant.
A key factor in delivering best-in-class SSC operations is close collaboration with an experienced banking partner.
12
12 | Treasury and Trade Solutions
Citi Perspectives | 13
Many companies have looked to revise their earnings and growth forecasts as a result of the impacts of depreciating currencies, consumer and business caution, and the resulting slowing of the economy. From a treasury perspective, these top-line impacts should prompt companies to redouble their efforts to improve expense management, streamline processes and enhance working capital.Steve Elms, EMEA Head, Corporate and Public Sector Sales, Treasury and Trade Solutions, Citi
14
The UK’s departure from the European Union will have significant short-, medium- and long-term impacts. EMEA Head of Corporate and Public Sector Sales Steve Elms is joined by fellow Treasury and Trade Solutions sector specialists John Murray, Roberto Di Stefano, Peter Cunningham and James Lee to assess the outlook for the airline, automotive, healthcare, and technology, media and telecoms sectors in the wake of the UK’s decision to leave.
Brexit: the effect on corporates
SECTOR SPOTLIGHT
14 | Treasury and Trade Solutions
Citi Perspectives | 15
Steve Elms EMEA Head, Corporate and Public Sector Sales, Treasury and Trade Solutions, Citi
While the unexpected outcome of the
UK referendum on European Union
(EU) membership — Brexit — created
short-term volatility, financial markets
have since largely recovered their
losses and sterling has regained
some ground against other major
currencies. In the short term little will
change for corporates active in the
UK: the UK’s exit from the EU may be
years away and corporates’ needs for
payments, receivables and treasury
management will continue as before.
However, with no commitment to
when Article 50, which will herald
at least two years of negotiations
in advance of the UK’s official exit,
will be triggered, or to how the UK’s
trading relationships with the EU
and the rest of the world will evolve,
companies face a significant period of
medium- and long-term uncertainty.
Many companies have looked to revise
their earnings and growth forecasts as
a result of the impacts of depreciating
currencies, consumer and business
caution, and the resulting slowing
of the economy. From a treasury
perspective, these top-line impacts
should prompt companies to redouble
their efforts to improve expense
management, streamline processes
and enhance working capital.
The outcome of negotiations will be
critical to determining to what extent
certain corporate functions will
continue to operate in the UK.
We are seeing many clients adopt
a wait-and-see approach before
making any wide-ranging strategic
and treasury decisions, and we
predict many companies will wait
until Article 50 is triggered so that
the UK’s goals will be clearer — for
instance, whether or not the UK will
establish a trading relationship with
the EU similar to that which Norway
or Switzerland has established.
The inability to access the Single
Market and the curtailing of EU tax
treaties and directives may trigger
certain company — and supply chain —
activities to relocate, which, in some
cases, may have an impact on the
location of regional treasury centers
(RTCs) or in-house banks. But it should
be put into context: measures such
as section 385 of the US Internal
Revenue Code and the OECD/G20 Base
Erosion and Profit Shifting project are
seen as having as significant an effect
on RTCs, in-house banks and pooling
structures as Brexit. Nevertheless,
the UK should remain an attractive
environment for such functions given
its secure, business-friendly regime
and ability to provide and attract
talent, all within the close proximity
of global banking partners.
The inability to access the Single Market and the curtailing of EU tax treaties and directives may trigger certain company and supply chain activities to relocate.
16 | Treasury and Trade Solutions
AirlinesThe airline sector is crucial to the UK. It contributes
USD100 billion to the economy and is tied to 1.3 million
UK jobs. In 2015, there were 160 million trips from the UK,
two-thirds of which involved travel to Europe.1
Uncertainty following the vote to leave has already led to
reduced forecasts from Ryanair, easyJet, IAG and Lufthansa:
the latter three have issued profit warnings. Earnings are
likely to come under pressure from a weaker pound and
slowing GDP growth. As a result, traveler numbers are
expected to fall by 3%-5% (reducing airline yield) as it is
suspected that foreign holiday costs increase and consumer
confidence falls.2
In response, airlines are reviewing
their capacity needs. Ryanair has
confirmed that it will reduce capacity
at Stansted and focus on its future
growth in EU airports, while Delta
Airlines plans a cut in transatlantic
capacity to the UK this winter.
Regulatory change is anticipated as
the greatest challenge facing airlines.
The regulation within the EU aviation
market has produced safe, efficient,
and economical air connectivity across
Europe, while the EU and US Open Skies
agreement — which allows carriers from
either market unlimited access to the
other — has benefited all carriers.
Both markets are potentially
threatened by Brexit. Ideally the UK
will remain part of the European
Common Aviation Area (ECAA),
which would give UK-based airlines
continued access to all EU airports.
However, this would require
acceptance of EU aviation law across
all areas limiting the UK’s ability to
define its own policy. The alternative
would be to negotiate a bilateral
agreement, similar to that between
the EU and Switzerland. Without
a successful agreement, there is a
possibility that UK-based airlines, such
as easyJet, will no longer be able to
operate intra-EU routes. The UK may
also need to negotiate agreements
with other countries such as the US.
Overall, the UK leaving the EU could
represent a huge challenge for UK-
based airlines, which, in addition to
considering its strategic implications,
must also review their cash, liquidity,
and treasury structures, which, in
turn, could lead to them to seek
advice on their options.
John MurrayEMEA Sector Head, Industrials, Treasury and Trade Solutions, Citi
Citi Perspectives | 17
HealthcareThe impact of Brexit on the healthcare sector is likely to
be significant and varied. For pharmaceutical companies,
Brexit could reduce sales if an economic downturn leads
to reduced spending on the National Health Service,
although the UK is just 3% of global sales (according to
Intercontinental Marketing Services).
More importantly, Europe accounts for 56% of UK
pharmaceutical exports: any change in trading rules
could have major consequences.3 Similarly, the potential
implementation of new manufacturing and safety standards
in the UK could increase costs.
The UK is a global center of excellence for research and
development. However, it relies heavily on EU funding:
GBP1 billion (equivalent to 25% of public funding) comes
from the European Research Council and could be lost
following Brexit.4 It is unclear if the UK government will
have the capacity or appetite to replace this funding: one
alternative could be increased pressure on the private
sector to invest more (it contributes the equivalent of
1.06% of GDP towards R&D, below the EU average and
80% lower than German businesses).5
Opting out of EU clinical trial
regulations could affect adjacent
services, such as contract research
organizations: the UK currently ranks
first in the EU for the number of
phase I trials, and second or third for
phase II and III trials.
Brexit could result in the relocation
of the European Medicines Agency
(EMA). It employs 600 people in
London and, more importantly,
approves drugs across the EU: its
presence in London encourages
international pharmaceuticals
groups to locate their European
base in the UK, and foreign direct
investment may fall following the
EMA’s relocation. However, the post-
referendum announcement that
GlaxoSmithKline will invest GBP275
million in three British manufacturing
sites is encouraging. Yet, the EMA
leaving the UK could also result in
delays in licensing and approving
new drugs, affecting patients and
increasing costs.
Given the absence of detail about
Brexit, corporate treasuries should
focus on contingency planning
in relation to cash management
structures and group legal structures
(i.e. which legal vehicle manufactures
products, earns royalties, and
distributes to end markets). In
addition, given margin compression
as a result of a more complex
regulatory environment — as well as
the potential pressure to increase
R&D investment — corporates may
look to fund this by increased free
cash generation through improved
working capital practices.
Peter Cunningham EMEA Sector Head, Consumer and Healthcare, Treasury and Trade Solutions, Citi
18 | Treasury and Trade Solutions
AutomotiveThe UK produced 1.6 million cars in 2015 — making it the
third-largest producer in Europe — and is home to 16 of
the world’s 20 biggest automotive suppliers that produce
locally. Brexit, therefore, may not only have an impact on
the UK economy but on the global economy.
Leaving the EU generates four main risks for the UK auto
sector. Immediate risks include sterling depreciation,
which, while benefiting exports, will result in increased
costs of imported parts. Meanwhile, currency-hedging
Roberto Di Stefano Italy Sector Head, Automotive, Treasury and Trade Solutions, Citi
costs are expected to rise, especially
for non-UK companies, with significant
translational effects. In addition,
Brexit could reduce economic growth
in the UK and in the EU. Consumer
spending on autos could fall as a
result: in response, some non-UK
companies could freeze planned
UK plant investments. This could
present challenges given the need
for significant investment in new
auto technology.
In the medium and long term, the
auto sector faces greater risks. Since
77% of passenger cars produced in
the UK are exported — 44% to the
EU — the loss of tariff-free access to
the single market and other countries
that have free trade deals with the
EU would make exported vehicles
from the UK more expensive.6 Over
time, auto companies could respond
by shifting production, with low-cost
locations best positioned to benefit.
Furthermore, auto firms need to be
aware of the implications of Brexit
for other sectors, most notably
finance. Given their high leverage,
supply-chain finance requirements,
and complex treasury and cash
management structures, most
automotive companies have close
relationships with the City of London.
As the finance sector evolves after
Brexit, auto company treasurers
may need to reassess their banking
relationships if the UK potentially
loses its EU passport rights.
1 See The Impact of BREXIT on UK Air Transport, IATA, June 2016. 2 The Impact of BREXIT. 3 www.rolandberger.com/en/misc/press/Press-Release-Details_3458.html, last accessed on 2 August 2016. 4 www.cbi.org.uk/global-future/case_study02_pharmaceutical.html, last accessed on 2 August 2016. 5 See www.digital-science.com.
James Lee EMEA Sector Head, Technology, Media and Telecommunications, Treasury and Trade Solutions, Citi
Technology, media, andtelecommunications (TMT)The UK has become a leading global hub for tech startups.
This is driven by access to skilled workers from the UK and
overseas, the UK’s pro-digital agenda, access to investment
capital through the banking sector and venture capital,
and a favorable regulatory and political environment
encouraging entrepreneurship.
In 2015, new tech startups raised GBP1.3 billion in funding,
creating 20,000 jobs.7 However, these startups, including
fintech companies, are reliant on the freedom of movement
of international talent, which could be harder to attract
following Brexit.4 Similarly, the high level of investment
in the UK’s tech startups — by banks, venture capital and
tech incubators — could potentially be put at risk. Indeed in
the month following the referendum, USD200 million was
invested compared to USD340 million in the same period a
year earlier, reflecting the investor uncertainty surrounding
what the UK’s exit from the EU will actually mean.8
The UK’s fintech sector has been one of the few sectors
to enjoy impressive growth in recent years: it generated
GBP6.6 billion in revenue and around
GBP500 million of investment in
2015, and it employs 61,000 people,
representing 5% of the total financial
services market9. Uncertainty about
fintech companies’ ability to operate
easily across borders post-Brexit could
hamper fintech’s development.
For TMT companies, the potential
impact of Brexit on the current benign
regulatory environment is critical — for
example, for mobile network operators
(MNOs), European roaming charges are
due to be abolished across Europe from
2017, and it is unclear what will happen
post-Brexit for the UK MNOs. For fintech
companies, the Digital Single Market,
announced in May 2015 (and the UK’s
championing of this), should pave the
way for even greater Europe-wide
e-commerce. It is now unclear whether
UK consumers and companies will
benefit from these changes.
However, morale in the UK TMT sector
has been boosted both by SoftBank’s
acquisition of UK chip designer
Arm Holdings and Amazon’s post-
referendum announcement that it will
increase hiring and will open a series
of data centers by 2017 in the UK (a
core hub country for Amazon, where
Amazon has almost 16,000 employees).
As Amazon UK Country Manager Doug
Gurr said recently: “Amazon has Silicon
Valley jobs in the UK.” But for all TMT
companies active in the UK (and their
treasury teams), there is a need to
analyze the implications of Brexit — as
its character becomes clearer — and
seek support so that any potential
impact it might have can be minimized.
6 www.rolandberger.com/en/misc/press/Press-Release-Details_3458.html, last accessed on 2 August 2016. 7 www.londonandpartners.com/media-centre/press-releases/2016/20160725%20-%20Tech%20investment%2016%20H1, last accessed on 1 August 2016. 8 See www.londonandpartners.com. 9 www.consultancy.uk/news/3338/uk-fintech-capital-of-the-world-but-competition-is-heating, last accessed on 1 August 2016.
Citi Perspectives | 19
Regional treasury centers come of age in Latin America
20
Bringing treasury functions under one roof through a regional treasury center offers significant opportunities for standardization and optimization, but careful planning and execution are required to ensure the project achieves its goals.
SECTOR SPOTLIGHT
20 | Treasury and Trade Solutions
Citi Perspectives | 21
Gabriel Kirestian Latin America Sector Head, Branded Consumer Goods, Healthcare, Technology, Media and Telecommunications, Treasury and Trade Solutions, Citi
Corporates operating in Latin America
face a wide range of challenges.
Their treasurers need to support
the business as it seeks to grow
against a backdrop of macroeconomic
and geopolitical volatility in some
countries. At the same time, the
regulatory and tax landscape across
the region is shifting and technology
is advancing rapidly: digitization and
innovation are creating potential
risks, such as cybersecurity, but also
offering new opportunities, such as
Big Data analysis, for example.
Given this environment, many
companies are expanding the role
played by treasury and finance
and charging them with four main
goals. The first is to improve funding
efficiency through greater use of
internal funding and enhanced
working capital management. The
second is to manage regulatory
change effectively to address
challenges and harness opportunities.
Thirdly, treasury is being tasked with
transforming and centralizing itself.
A fourth objective is to leverage
technology in ways that offer a clear
return on investment.
Treasury’s response has been to
supercharge its standardization,
centralization, and optimization
strategy through the creation of
regional treasury centers (RTCs).
RTCs differ from shared service
centers (SSCs), which are typically
operational in nature and focus on
process optimization, often in relation
to high-volume low-value payments and
receivables. By contrast, RTCs play a
more varied and strategic role in terms
of treasury functions (although policy,
strategy, and procedures are usually set
by group treasury at corporate level).
The functions carried out by RTCs
differ between companies. However,
typically, RTCs fund business units,
manage liquidity and working capital,
and forecast cashflows. They identify
risks (including those associated with
regulatory change) and manage them
by executing hedging strategies for
foreign exchange, commodities, and
interest rates, as well as executing
trades associated with short-term
investment and trade instruments. In
most instances, RTCs coordinate bank
relationships and provide support to
the business, and in some companies,
they may also be responsible for
leveraging data and digitization to
drive change.
A four-phase approach to centralizationA project to create an RTC with
the objective of standardizing
and optimizing processes through
centralization must typically go
through four distinct phases to
achieve its desired results.
• Treasury should start with thorough
due-diligence and data-verification
reviews that cover every aspect of
how it functions. How many bank
relationships and accounts does
the group have in each country?
What functions do banks provide
and what type of transactions are
made by each business unit? And
how do banking regulations affect
the migration of certain treasury
operations to an RTC? Only by fully
understanding its existing structures
and relationships — and their
shortcomings — can treasury plan
and implement change successfully.
• Once a company has the
information it needs to make
22 | Treasury and Trade Solutions
decisions, it can begin to rationalize
its existing structures and
relationships. Many companies
operating in Latin America have
dozens of banks and hundreds of
accounts (often built up through M&A
activity or because local businesses
were responsible for establishing
bank relationships). In most cases, a
handful of key banks and a few dozen
accounts would deliver enhanced
visibility and control, greater
efficiency, and lower costs.
• Once rationalization has been put
in play, treasury can then task its
slimmed-down bank group with
standardization, requiring it to
use standard formats (such as
ISO 20022 XML) and common
connectivity standards, such as
SWIFT — one bank can be appointed
to receive information from the
others (using common standards)
to ensure centralized visibility. At
the same time, the complexity of
processes can be reduced and data
capture automated as part of the
introduction of best practices.
• Finally, treasury can move on to the
integration phase, deciding whether
to create an SSC or reduce in
number (or eliminate) local treasury
departments, for example, as well
as integrating systems across the
enterprise.
The path to treasury centralization Within the treasury, there are
multiple functions. Ultimately, it
may be desirable for all of them to
be centralized in an RTC. However,
such an aim is unlikely to be
realistic in the first place. Instead,
corporations should focus on the
standardization and the optimization
of those processes that are easiest
to centralize and that deliver the
greatest gains.
As described above, prioritizing
banking strategy and account
structures can be beneficial because
they can facilitate other aspects of
centralization. Information services
and regional visibility play a similar
role which can lead to a more
efficient centralized cashflow forecast
process that is usually followed by
local payments, supplier financing,
international payments, and tax and
custom payments. More challenging
steps that should come later in the
project management workflow include
purchasing, travel and entertainment
cards, FX centralization, and account
receivables management.
Managing an RTC project to a successful conclusionThe creation of an RTC involves
significant operational change for a
company. In order to minimize disruption
and maximize results and the pace
of change, careful preparation is
necessary. Treasury must begin with a
clear vision and scope for the project so
that benchmarks and timelines can be
established and progress evaluated at
multiple stages. To ensure organizational
support, the project must be publicized
by obtaining early buy-in from senior
figures within the company: local
operational resistance to centralization
should not be underestimated.
Establishing an RTC is a major
undertaking. But corporates do
not have to face the challenges
involved alone. Citi offers support,
expertise, and solutions that address
every aspect of standardization and
optimization, and it has a proven track
record of helping companies in Latin
America to implement effective RTCs.
Citi Perspectives | 23
24
SECTOR SPOTLIGHT
In the swirl of banking regulatory and interest-rate changes taking place in the Asia-Pacific region today, demands on corporate treasurers are intensifying. What key trends should they look out for in 2016 as they navigate a landscape marked by diverse legal frameworks, economic systems, commercial languages, and banking infrastructures?
three key trends
Navigating regulations, rates and risk in Asia:
24 | Treasury and Trade Solutions
Citi Perspectives | 25
Trend #1
Interest-rate environmentsIn 2015, we saw 24 rate changes across
key markets in Asia. Since entering
2016, we have had another eight rate
cuts — and counting — the most recent
following the Reserve Bank of Australia’s
announcement on 3 May that it had
reduced the target interest rate by
25 basis points (bps). Often, inflation
considerations are the main reasons for
such actions by central banks.
The impact of these rate cuts to
economic constituents, which include
individuals, companies, governments,
and many other organizations, is
considerable. In 2015 alone, this
amounted to 6% in value reduction
in Asia, which they would otherwise
have been able to create through their
assets earnings, or through liquidity
optimization. This is a phenomenal
change compared to the last decade,
when interest rates were generally
high in most Asian markets.
This is one of the dilemmas faced
in managing treasury today —
understanding the rate environment,
what strategies you can adopt, which
solutions, tools and platforms are best
for your organization when dealing
with these uncertainties, and what
methods you can deploy to bring that
value back to your organization.
For some treasurers, it could be
better refinancing short- to medium-
term debt or widening the range of
investments with a view to gain higher
yields. For others, it could be a simple
optimization of liquidity. While the
objectives can vary, the starting point
can be an honest evaluation of where
your cash is — is it in the fungible
markets where cash can be moved or is
it in trapped markets? Is the cash used
well domestically or is there a need to
look at transfers or lending out to HQ
or another subsidiary? Then, if you
actually have the right solutions and
systems in place to manage, you can
gain visibility.
Rate cuts are one salvo in the
monetary policy arsenal — the other
new development is negative interest
rates. For some markets, this is a
chance to reinvigorate their economies
when all other monetary policy tools
are exhausted. This is an unorthodox
view, ushering in a new era for central
banks globally.
Negative interest rates are things we
have seen more of in Europe, but their
implications are far broader. Within
Asia, Japan has been the latest to join
the stream. In January 2016, when the
Bank of Japan announced its negative-
rate policies, the financial markets
reacted disproportionately, even
though the policy applied mainly to
selected current-account deposits that
banks held with the Bank of Japan.
Since the announcement, Japanese
government bonds have seen volatile
price swings, mainly with longer-dated
instruments.
Nishami Dharmaratne Asia Pacific Head, Regional Liquidity and Investment Solutions, Multinational Client Segment, Treasury and Trade Solutions, Citi
Deborah Mur Asia Pacific Sector Head, Industrials, Energy, Power and Chemicals, Treasury and Trade Solutions, Citi
26 | Treasury and Trade Solutions
However, it is important not to make
assumptions, as the way negative
interest rates have been implemented
reflect how the practice in each
market can be very different. The
general expectation is that banks
would review the impact and possibly
implement charges for those deposits
held in the currencies that are yielding
negatively. Some regulators recognize
the concept, but are struggling to
understand its execution so there can
be variations in the process.
China and Korea, for example, are not
necessarily considering whether banks
can go ahead and impose a charge, but
are reviewing the best approach for
this concept.
What is more important for the treasurer
is carefully examining the billing
currencies, understanding the charge
methodologies in each market, and
evaluating the pros and cons of liquidity
held in these currencies. Do not forget
to consider the long-term view of these
currencies before making decisions.
Trend #2Varying degrees of regulationsOne significant regulatory impact
that is well known is Basel III, which is
primarily a measure to ensure banks
are safe and sound from a capital,
leverage and liquidity perspective. While
this is mainly a banking regulation,
corporates will start to feel the impact
as their partner banks begin adopting
various strategies to deal with it. In
particular, both short-term (less than
30 days) and long-term (beyond 1 year)
views on liquidity measures will become
extremely important to banks.
This means that banks will closely
monitor the deposit values and
operational nature of the bank
accounts and the level of stability of
the deposits. Treasurers will need to
evaluate the value of the deposits
created and what the core liquidity is
versus strategic liquidity.
The treatment of these two types
of liquidity can be different — hence
earning power can vary.
Another factor for consideration is
the general regulatory environment
itself, which affects the way companies
operate. This is particularly complex
in Asia, where there are nearly 16
markets, all of which have their own
legislative systems, tax systems, and
company legislations, which define
many different intercompany rules,
thin capital thresholds, and numerous
commercial guidelines.
Take, for example, Vietnam’s
announcement last year that US
dollars would not attract any interest
onshore. If yours is a USD-invoicing
company, your onshore USD liquidity
will no longer attract any yield.
Or consider Indonesia. Indonesian
requirements are increasingly focused
on commercial transactions. For a start,
every commercial contract in Indonesia
must be in the local Bahasa language.
Secondly, every commercial transaction
needs to be settled in Indonesian
rupiah. If you are a dollar-based
company, you are typically invoicing in
dollars, which was allowed in the past,
but which is no longer the case. You will
need to consider better ways to draft
your invoices, collect in local currency,
and then decide what to do with the
rupiah once you have collected it.
If companies do not have the on-
ground expertise or the footprint
Citi Perspectives | 27
to deal with that, they can turn to a
banking partner equipped to support
them and provide solutions.
Over in India, the Companies Act
2013, which restricts the ability of
private and public companies to
conduct intercompany lending if they
share the same directors, makes
multi-entity pooling a challenge.
However, we have found that more
companies are exploring multi-bank
cash concentration to enhance their
domestic liquidity management
efficiency.
By that same token, countries like
Thailand had introduced recent
relaxation measures and treasury
incentives to facilitate fund flows into
Thailand. Extracting liquidity out of the
country for optimization at regional
or global levels is still a challenge, but
these are a welcome start.
Trend #3Liquidity transferability and convertibilityWe have observed a spectrum of
markets within Asia’s regulatory
landscape. There are the developed
and flexible domestic and cross-border
markets of Singapore, Hong Kong,
Japan, Australia, and New Zealand.
And there are the semi-regulated
markets such as Indonesia, Malaysia,
Philippines, and China, where the view
on transferability of their currency
and convertibility of the currency is
somewhat restrictive.
How transferable a currency is, and how
flexible it is in terms of convertibility,
creates opportunities for companies.
The good news is that more and more
markets are opening up, as in the case
of China and Thailand.
28 | Treasury and Trade Solutions
But some countries are still
viewed as trapped markets — these
would include India, Vietnam, and
Bangladesh, among others. If you
enter these markets, where you
need to have some self-funding
arrangements, it would make a lot of
sense to look at a domestic solution
in those countries and have a buffer
of regional pools. In a landscape like
Asia’s, a corporate should define
what the best liquidity optimization
strategy would be — whether it should
be a domestic solution to support the
business model in trapped markets or
a potential regional solution for the
fungible markets where liquidity is
easily transferable.
When it is a restricted or semi-
restricted market, companies can
keep some or all of the cash in the
country to meet their liquidity needs,
given the challenges associated
with cash forecasting or time zones.
Corporates can avoid potential loss
of value when they choose in-country
centralization options. On the
other hand, where companies have
the flexibility to comingle liquidity
among multiple entities and multiple
countries, then they can opt for
regional or global pools.
Looking aheadAs treasurers navigate an uncertain
landscape, the vision is for flexible
cash management systems, which at
least support their day-to-day cash
management operations. Treasurers
should also ask if the solutions they
have today will allow them to stretch
themselves, to take advantage of
opportunities that will enhance
liquidity use and achieve better yields
with the end objective of putting in
place an optimal liquidity structure.
They should also evaluate liquidity
in terms of operational and strategic
cash, and form a view on whether
strategic cash is needed in the short
run or whether it can be deployed
with high-yield instruments over the
medium or long term. This allows a
treasurer to enhance earnings from
excess liquidity. In day-to-day liquidity
requirements, what companies are
increasingly looking for is speed and
efficiency of liquidity solutions. This
makes it important to have the right
banking partner to provide the best
possible platform and give you very
quick service in the movement of your
cash, whether that movement is global,
regional or in-country.
In most cases, we find companies are
also increasingly looking at the depth
and breadth of products and solutions
that can support multiple currencies,
multiple entities, multiple residencies,
and multiple countries, with a view to
mobilizing their liquidity effectively.
In summary, treasurers should
keep three primary goals in mind
when navigating this ever-changing
landscape: operational efficiency, along
with the integration and optimization
of liquidity.
Treasurers should ask if the solutions they have today allow them to stretch themselves, to take advantage of opportunities that will enhance liquidity use and achieve better yield.
Citi Perspectives | 29
30 | Treasury and Trade Solutions
30
30 | Treasury and Trade Solutions
Citi Perspectives | 31Citi Perspectives | 31
An optimal experience has to package complex processes into one that is simple, intuitive, seamless and engaging.JP Jolly, Global Head, Channel and Enterprise Services, Treasury and Trade Solutions, Citi
INNOVATION SPOTLIGHT
Banks must carefully balance innovation and security as they work to overcome client onboarding pain points.
Taking onboarding into the 21st century
32
32 | Treasury and Trade Solutions
Citi Perspectives | 33
Sabine McIntosh Global Head, Account Services, Treasury and Trade Solutions, Citi
The identification process creates a
foundation of trust that is critical to
establishing a successful relationship. It
ensures that banks can only act in line
with defined regulatory and corporate
governance and on the instruction
of authorized individuals. Regulators
are cautious in approving changes
since there is significant importance
placed on client identification and the
document generation process, which
is critical to maintaining the integrity
of the financial system. This has an
impact on documentation issued by
banks, which operate as gatekeepers
to both regulatory and corporate client
identification requirements.
Once a client’s credentials have been
confirmed, opening a functional
account typically requires a significant
amount of documentation to be
mailed to clients, which must be
checked and signed, sometimes by
multiple signatories across the client
company opening the account, such as
treasurers, corporate secretaries, and/
or cash management directors. The
need for multiple signatures, often from
people who are not present in the same
country and/or who travel frequently,
can slow down the documentation
process. There is therefore an
opportunity to digitize and automate
the client-approval process.
Banks have embarked on a journey of
innovation, and are seeking to raise
standards and promote best practices.
Channel solutions must be secure.
Clients, banks, and regulators must be
aware of the potential risks of their
use. However, effectively implemented
technology solutions can potentially
enhance security by providing
electronic audit trails and could serve to
help increase the level of trust between
clients and banks, therefore resulting in
elevating the client experience.
Third-party utilities Know-your-customer (KYC) screening
is a cumbersome and administratively
taxing exercise for corporates and
banks. It involves due diligence,
document collection, and data entry.
In recent years, technology has transformed nearly every facet of our personal and business lives, improving convenience and control. Many clients would like to see similar innovations take hold in the financial services onboarding process, which consists of two principal elements: identification and the setting-up of services.
Rob Schlaff Market and Network Manager, Account Services, Treasury and Trade Solutions, Citi
34 | Treasury and Trade Solutions
However, as banks’ data requirements
and client bases overlap, digitized
KYC information — shared via third-
party data aggregators — can improve
convenience and efficiency in the
onboarding process for clients and
for banks.
Although SWIFT has such a utility in
pilot for financial institutions, industry
utilities for corporates are still in their
infancy. It is, however, anticipated that
this is set to change with ongoing
progress being made.
A variety of fintech companies,
consultancies, and data providers have
formed partnerships to create utilities
to collect or aggregate client KYC data.
While clients need to ensure the data
shared by the utility is accurate and
secure, banks retain responsibility for
KYC even when using a utility.
To date, regulators have not explicitly
supported KYC utilities: if they do,
utilities could rapidly gain momentum
creating convenient depositories
of corporate information, thereby
speeding up the KYC component of the
onboarding process.
Signature management technology Industry-wide initiatives are already
helping to make the bank account-
opening process quicker and easier.
One growing challenge for corporates
is managing global signatories on
their accounts. An industry utility
called SignatureNet enables financial
institutions to securely store, retrieve,
and manage their approved signatory
lists electronically, as an alternative
to inefficient, time-consuming, and
expensive traditional paper-based
signature books.
SignatureNet has been widely
adopted, especially by financial
institutions in Europe and the Middle
East, which have consequently
embraced it as a convenient tool
to improve operational efficiency.
Citi Account Services utilizes
SignatureNet to verify the signatures
of financial institution clients’
authorized signers as part of account
opening in the US and the UK.
Clients benefit from reduced paper
documentation as they no longer
need to provide physical signature
books when they open an account.
SignatureNet is also easily updated
and therefore more reliable while
offering increased security as there is
a clear audit trail.
DocuSign is a leading electronic
signature technology globally, which
facilitates electronic exchanges
of account-related contracts and
signed documents by providing an
authentication mechanism for digital
signatures. Adoption of DocuSign
by corporates is increasing and a
number of banks are seeking to take
advantage of its functionality.
An example of its use can be seen at
Citibank, N.A., Sydney Branch, where
it is now possible to accept electronic
signatures for Australian account-
opening and account-maintenance
documents from clients using
DocuSign. This means original paper
documents with wet signatures are
no longer required. However, some
anti-money-laundering, identification
certification, and banking mandate
documents will remain paper-based
because of local legal requirements.
INNOVATION SPOTLIGHT
Citi Perspectives | 35
Digitization of branches To accelerate the account-opening
process and the setting-up of services,
banks in a number of western
countries have made it easier for
clients to exchange digital information
with their banks via email or using
electronic bank account management
(eBAM) solutions. Client adoption of
digitized solutions/channels resulted
in a 55% improvement in the speed of
account opening at Citi in 2015.
In North America, Citi’s Electronic
Document Submission process now
allows most documents associated with
account opening and maintenance to
be scanned and sent via secure email
or uploaded into the eBAM module
of CitiDirect BE®, Citi’s electronic
banking platform. The scanned copies
replace their original counterparts and
no paper-copy follow-up is typically
required. This same process is now
being piloted in Western Europe.
Although some documents still
require a wet signature, the use of
an electronic copy of a document
means that there are no delays due
to mailing time. Moreover, executives
in different locations can easily add
their signatures to the document
without it being mailed around the
world, while at the same time providing
greater transparency into the process
as they retain electronic copies of all
documents that are sent.
Banks also have an opportunity to
create greater efficiencies in the
process by reusing existing data they
hold to pre-fill documentation on behalf
of clients where allowed by regulators.
Citi has already adopted this practice
in three markets and anticipates that
it will roll it out to more. Citi continues
to invest in new technologies to
further ease the burden on clients of
completing required documentation.
Working towards a simpler future Citi is committed to introducing
innovations to the onboarding process,
not only because they improve
convenience for clients, but because
— properly executed — they improve
security and the overall experience
clients have when opening and
maintaining their accounts. In this
journey of innovation, digitization
can provide a more secure and
transparent way of exchanging data,
which establishes the identity and
entitlements of individuals acting
on behalf of a company, improving
security across the client relationship
and reducing risk for the client and
their financial services providers.
With the emergence of third-party
utilities in the corporate onboarding
space, there are further efficiencies
to be gained. This is especially true
for companies that have relationships
with several banks across multiple
jurisdictions. Such utilities should help
to accelerate account opening and
maintenance processes in a safe and
regulated manner.
Corporates will continue to reap the
benefits of central depositories of
data held at utilities and of the wider
technological advancements in the
onboarding process. These will support
the sharing of real-time information
and increase operational efficiencies
by parting with traditional paper-based
practices. It seems somewhat certain
that in most countries many parts of
the onboarding process will continue
to evolve, improving convenience,
efficiency and — most importantly
— security for both clients and their
financial services providers.
Cybersecurity: the impact to the financial supply chain
36
INNOVATION SPOTLIGHT
It’s no longer enough for corporates and banks to simply react to cybersecurity risks — they must be proactive and anticipate what adversaries will do next.
36 | Treasury and Trade Solutions
Citi Perspectives | 37
Raj Shenoy Global Head, Digital Security, Treasury and Trade Solutions, Citi
The gap is widening between criminals’
ability to attack and corporates’
and governments’ ability to defend
themselves: it takes an average of 265
days to discover a network breach. To
close this gap, Citi shares information
that may be red flags of potential
breaches with clients, other banks, and
regulators, helping to prevent attacks
to their own systems in the future. By
partnering together, participants will
make the financial ecosystem stronger.
Understanding the motivation of attackersTo develop an effective security
strategy, it is necessary to understand
who attacks corporates, how they do
it, and why. There are five cyberthreat
actors — nation-states, cybercrime,
terrorism, hacktivism, and insiders —
each with different targets, methods,
and objectives.
Nation-state actors aim to steal
intellectual property and engage in
intelligence collection to advance
national interests. They are difficult
to defend against because of their
potentially significant resources and
advanced capabilities.
Cybercrime actors are mainly
motivated by financial gain, but can
cause damage when monetization
attempts fail. Their typical methods
include spear phishing and similar
social engineering techniques,
automated crime tools, fraud, botnet-
enabled distributed denial-of-service
attacks, and cyberextortion or
ransomware.
Terrorist actors are politically or
ideologically motivated and aim
to instill fear. Typical methods are
destructive cyberattacks, designed
Cybercrime, an attempt to access or damage a computer network or system to steal data or money, costs the global economy an estimated USD445 billion worldwide every year in direct damage and recovery costs. The number of cyberattacks is growing as companies digitize and the number of connections to the internet grows. By 2020, there will be an estimated 50 billion internet connections compared to 15 billion currently: each is a potential risk.
38 | Treasury and Trade Solutions
to destroy, degrade, disrupt, or deny
system operation, and cyber-enabled
functions to recruit, incite, train, plan,
and finance operations.
Hacktivists generally seek publicity to
further their geopolitical or social agenda
and usually operate disruptive campaigns
primarily via distributed denial-of-service
attacks and website defacements.
Insiders are potentially the greatest
threat to corporations. They may seek
financial gain or wish to cause harm for
a perceived wrong. Corporates need
to adopt a different strategy to detect
and defeat insiders given their inside
knowledge, which can more easily
enable them to steal data, conduct
fraud, or cause damage undetected.
Defeating this wide range of attackers,
who use a huge and evolving range of
methods, is challenging: corporates
have to get it right 100% of the time,
whereas criminals only need to get
it right once. However, in reality,
corporates have multiple opportunities
to successfully prevent or defeat
attacks: the reconnaissance phase, the
initial compromise, the establishment
of a foothold, the ability to escalate
privileges, and the ability to exfiltrate
data. Attackers must go through each
phase for a successful attack. That
gives corporates or banks the ability
to customize defenses for each stage,
depending on the type of actor.
At Citi, this customization of defenses
occurs at Citi Security Operations
Centers (SOCs), which house teams
that constantly monitor for intrusions
and which collect data on patterns of
activity (such as unsuccessful defensive
measures so that lessons can be
learned). Citi Cybersecurity Fusion
Centers (CSFCs) comprise multiple
cybersecurity teams from across Citi
to better attribute the threats, see
if such threats are affecting other
organizations, and determine what
lessons Citi might learn from them. The
overall goal is to stop the adversary at
the reconnaissance phase before they
can actually conduct their cyberattacks.
The impact on treasuryAttacks on the treasury can take a
number of forms. One of the most
common is treasurer impersonation,
which involves a combination of
technology and social engineering.
For example, a treasurer may update
their social network account with
an event they will be speaking at.
A hacker uses that site as an entry
point and gains access via an online
brute-force attack to guess the
treasurer’s login ID and password.
The hacker follows up by making
connections with the treasurer’s
associates (such as key suppliers or
employees) linked to that account
before sending a social networking
site message to all associates asking
them, for example, to click on a link
to the upcoming conference at which
the treasurer is speaking. These
users are then compromised by
malware when they click on the link.
The malware infection enables
the hacker to compromise the
credentials of the contacted parties’
email accounts and send directions
to the treasurer’s account payable
INNOVATION SPOTLIGHT
Business, both externally and internally, is increasingly dependent on electronic interaction and communications across a broad spectrum of partners inside and outside the company.
Citi Perspectives | 39
colleague to change vendor bank
details and transfer funds. Similar
attacks may use a telephone call to
request a payment (often claiming
that, for business reasons, such as an
M&A or regulations, the details of the
request must be kept secret).
The impact on the financial supply chainBusiness, both externally and
internally, is increasingly dependent
on electronic interaction and
communications across a broad
spectrum of partners inside and
outside the company. For example,
treasury interacts externally with
its banks, vendors that may be
performing outsourcing functions,
and suppliers; and internally with
functions such as technology or
human resources. It is critical to
ensure that end-to-end security is in
place across all of these interactions.
Key controls to safeguard the company
include but are not limited to:
• Data protection: information,
including customers’ or suppliers’
details, is as great a target for
criminals as transactions, as it can
be easily monetized.
• Third-party information-security
assessment: all vendors must
have appropriate controls. Regular
questionnaires, reviews, and audits
are helpful to access new partners’
security measures.
• Security incident management:
corporates need to have procedures
so people know what to do if
security is breached.
• Vulnerability assessment: controls
should be tested periodically, ideally
by a third party, using tools similar
to those used by hackers.
• Global ID administration: there
must be a prompt method to update,
modify, or delete access to systems
as employees’ roles change to avoid
vulnerabilities.
• Privileged user-managed access:
entitlements to sensitive internal and
external systems and networks must
be appropriate for each employee.
• Data: reports can be used to monitor
and identify potential problems as
early as possible to trigger security
incident-management processes.
Alternatively, data can be mined to
identify trends and best practices
relating to user access, for example.
40 | Treasury and Trade Solutions
Staff must be thoroughly screened and then trained on cyberthreats and potential fraud.
Security best practices Improving internal fraud prevention
and the reaction to such on discovery
depends on prevention and post-attack
mitigation within the financial center.
Prevention can be split into three
areas, each of which has distinct
best practices that enhance
security. Internal controls include
implementing electronic payments
for recurring check disbursements,
using additional levels of control
for new payee authentication, and
minimizing spare check stock and
maintaining tight control over
inventory. In addition, surprise audits
should be conducted and exception
items and account activity should be
reviewed on a daily basis.
Transaction controls are one of the
most important security areas for
corporates. Robust controls should
be in place for access to systems
and data, and locked beneficiary
templates (preformats) should be
used for payments to help prevent
unauthorized changes. Citi also
recommends the use of separate
deposit and disbursement accounts to
allow depository accounts to block all
check presentment.
Human resources risk mitigation
is also essential. Staff must be
thoroughly screened and then
trained on cyberthreats and potential
fraud. Those in financially sensitive
assignments must be periodically
rotated or have mandatory absence
periods so there is no single point
of potential failure and threats are
mitigated. Maker-checker segregation
of responsibilities should be enforced,
and this should be supported in
system workflows.
While prevention is clearly a priority,
it is important to have post-attack
mitigation and recovery plans in place
to quickly and effectively respond to
an incident. These include the issuing
of alerts and reminders so staff know
what to do in the event of an actual or
potential compromise. It should also
be clear whom to contact at the bank
should suspicious activity occur.
Furthermore, a playbook on how to
manage a security incident should be
in place with practice drills to insure
readiness. The faster an action is taken,
the more likely it is that funds will be
recovered or damage prevented.
INNOVATION SPOTLIGHT
While prevention is clearly a priority, it is important to have post-attack mitigation and recovery plans in place to quickly and effectively respond to an incident.
Citi Perspectives | 41
INNOVATION SPOTLIGHT
42 | Treasury and Trade Solutions
42
Commodity prices: the impact on trade finance
Citi Perspectives | 43
Kris Van Broekhoven Global Head, Trade Commodity Finance, Treasury and Trade Solutions, Citi
Commodity prices have dominated the
headlines over the past 18 months, with
the oil price more than halving from
its peak in 2014, and metals prices
also falling sharply. For commodity-
producing countries, price declines
have been a significant economic
shock, which has rippled into the
global economy. Price declines have
also created challenges for commodity
producers and raised concerns among
regulators and investors about banks’
exposure to commodities.
Commodity prices have always been
somewhat volatile and both oil and
metals have suffered significant
setbacks in the past. The current
malaise is different, however, because
of the speed of the oil price fall and the
simultaneous decline of oil and metals
prices: historically these commodities’
cycles were uncorrelated.
The economic slowdown in China,
a market that, until recently, had
been a major contributor to global
economic growth and trade in the
post-crisis period, helps to explain both
developments. Demand for commodities
in China, and to a lesser extent in other
leading emerging markets, has fallen
steeply as the country’s economic
growth has slowed. Given the mismatch
between demand and supply for many
commodities, prices have subsequently
come under pressure.
Surplus trade finance hits profitsFor the trade finance world, the fall in
commodity prices has had dramatic
repercussions. In 2014, before the
oil price collapsed, World Trade
Organization figures showed that
80-90% of world trade relied on the
provision of trade finance via banks
and insurance companies. In 2014, the
trade finance market was worth about
USD18 trillion a year, USD3 trillion of
which was related to oil. As the oil
price has halved so the value of oil
traded has also halved (even if the
quantities are identical).
For banks serving the trade finance
market, this rapid shrinking of the
The recent fall in commodity prices has had an impact on trade finance banks and generally reduced the availability of financing available to many companies in the sector. But while banks’ profits — and global growth — may be affected, concerns about banks’ exposure to commodities may be largely unwarranted.
44 | Treasury and Trade Solutions
market has been problematic. Even
before the recent commodity price
falls, there was intense competition in
trade finance, which resulted in tight
pricing. The steep falls in demand
over the past year have contributed
to an even greater trade finance
liquidity surplus, further intensifying
competition and driving prices down.
Lower volumes and lower revenues
may result in reduced profits for banks.
So far there have been no major bank
exits from trade finance, although
some banks have reorganized their
trade finance operations. Trade finance
has traditionally had a relatively high
percentage of fixed costs, such as
platforms and expertise. Indeed, costs
have increased as a result of tougher
regulations and increased compliance
requirements. For banks committed
to retaining a trade finance presence,
there is therefore little choice but to
compete on price to try to win business
and generate volume.
Financing availability differs for corporatesSurplus liquidity and increased
competition among trade finance
banks sound like an attractive
proposition for corporates seeking
financing. The largest commodity
producers in the world, classed as
tier-one clients, may benefit from
oversupply. Similarly, other global
producers that previously accessed
international debt capital markets
now find that, while bond investor
appetite has diminished, funding may
still be available from banks (as well as
commodity traders, which previously
were unable to sign up the biggest
producers for supply agreements).
However, for the majority of potential
borrowers, trade finance facilities
appear to be becoming harder to
access as banks are withdrawing
credit to help ensure their balance
sheets remain efficient.
Banks are unable to provide
trade finance to many commodity
companies primarily because of
commodity price falls. Given the
low price environment, the ability of
upstream producers of oil and metals
to generate cashflow is weaker. As a
result, their leverage has increased,
heightening their credit risk and
making banks less willing to lend to
them. These companies may have
few options apart from cutting costs
(including by asset sales) to lower
leverage and try to secure access
to credit.
The risks for global growthOne of the dangers for the global
economy is that the decline in the
availability of trade finance to many
commodity companies — partly as
a result of their worsening credit
quality due to commodity price falls,
but also as a result of more stringent
regulatory requirements — will reduce
growth. The main thrust of post-crisis
regulatory change has been to help
strengthen the financial system and
reduce systematic risk and is therefore
beneficial. However, there is potential
While the trade finance industry faces significant challenges as a result of the fall in commodity prices and increased regulatory requirements, it is important to recognize that trade finance still remains a viable business and a critical facilitator of global trade.
INNOVATION SPOTLIGHT
Citi Perspectives | 45
for unintended consequences from
new regulations if banks’ ability to
provide trade finance is reduced: global
trade and growth could be hampered.
Regulatory changes, such as Basel
III, and compliance initiatives, such
as know-your-customer (KYC), have
also had practical implications for the
provision of trade finance by banks.
For example, account opening and
the deal-approval process can now
take significantly longer because of
the checks that banks are obliged to
perform. Banks have also had to make
sizeable infrastructure investments
to assist in meeting regulatory
requirements. To date, fierce
competition may prevent these costs
from being passed on to clients, but it
is expected that repricing will occur at
some time in the future.
Grounds for optimismWhile the trade finance industry faces
significant challenges as a result
of the fall in commodity prices and
increased regulatory requirements, it
is important to recognize that trade
finance still remains a viable business
and a critical facilitator of global
trade. The bulk of trade finance is
short term, self-liquidating, and low
risk: commodity price falls do not
increase risk in banks’ commodity
trade finance portfolios. While
longer-dated financing is affected by
commodity price falls, banks usually
have risk mitigation embedded into
borrowing structures.
It is also important to note that while
falling oil prices have a negative
impact on commodity producers and
commodity-exporting countries, some
of which have suffered credit-rating
downgrades and had to reduce public
spending, the falls may be beneficial
for oil-importing regions, such as the
US and Europe, and can be expected
to stimulate economic growth.
Similarly, lower commodity prices may
provide a boost for companies that
use commodities as an input, as their
working capital needs and leverage fall.
46 | Treasury and Trade Solutions
46
Citi’s global network, combined with the local depth of our solutions and advisory services, innovation, and industry expertise, can play a vital role in helping treasurers take advantage of growing opportunities.Ebru Pakcan, Global Head, Payments and Receivables, Treasury and Trade Solutions, Citi
Citi Perspectives | 47
48 | Treasury and Trade Solutions
Jeffrey A Miller North America Sector Head, Energy, Power and Chemicals, Treasury and Trade Solutions, Citi
Kelvin Ang Americas Head, Treasury Advisory Group, Treasury and Trade Solutions, Citi
Ambrish Bansal North America Head, Market Management, Treasury and Trade Solutions, Citi
Corporate split or spinoff: finance in the hot seat Corporate restructuring activities continue unabated around the world. In 2015, there were more than 44,000 merger and acquisition (M&A) transactions totaling over USD4.5 trillion.1 A growing number of these restructuring transactions are resulting in corporate splits or spinoffs. During the past year, there were 95 spinoffs globally, totaling nearly USD260 billion in value, a record, and more than twice the total value in 2014 (USD127 billion).
48
A look at some key drivers of recent spinoff activity2
Improving operational efficiency
Focusing on core competencies
Paying down debt
Unlocking value by selling non-core assets
Prompting from shareholder activists
Keeping pace with competitors
Meeting antitrust requirements
Generating tax benefits
56% 40% 36%
24% 20% 16%
4% 4%
Citi Perspectives | 49
The reasons behind this record-
high activity vary by industry, but
several factors, such as improving
operational efficiency, focusing
on core competencies, and paying
down debt are the primary causes
(see chart below). And as this M&A
activity has increased, so too have
the challenges of restructuring these
global organizations.
Whether it be the office of the
chief financial officer, treasury,
procurement, accounts payables, or
accounts receivables, the finance
function is in the hot seat when it
comes to dealing with the implications
of restructuring throughout the
lifecycle of spinoff activities.
The important role of treasury in splits and spinoffs
In 2015, according to the Wall Street
Journal, spinoffs made up 53% of
corporate actions, followed by share
buybacks and joint ventures.3 When
it comes to restructuring a company,
spinoffs remain one of the most
popular ways, other than mergers and
acquisitions, to accomplish this goal.
As corporate activities become
more complex, it becomes clear that
planning and managing transaction
flows following a split or spinoff
falls firmly in the lap of treasury
professionals.
50 | Treasury and Trade Solutions
Overcoming the challenges of a split or spinoff When a split or spinoff occurs, the
challenge is to divide one efficient
treasury team into two, but this type
of “cloning” doesn’t always yield a
successful outcome. Simply replicating
the parent company’s treasury
structure in the new spinoff company
may bring with it inefficiencies in
the number of bank accounts, the
number of bank relationships, and the
way cash is concentrated. Since the
new company may involve different
lines of businesses where the sales
and the supply chain models are not
exactly the same, those inefficiencies
may become more conspicuous.
However, a well trained treasury
team should be sufficiently versatile
and knowledgeable to replicate
sound treasury policies and efficient
processes in the spun-off entity to
ensure successful operations.
An example of the challenges presented
by a spinoff can be found in the case
of the USD6 billion performance
chemicals business of DuPont, which
has a manufacturing and sales footprint
in more than 130 countries. Spun off
in July 2015, the new company, known
as Chemours, needed to survive and
thrive amid a cyclical cash-to-cash
cycle (inventory is built throughout the
year, but the majority of sales occurs
in Q3/4) in which cash that was tied up
in working capital had to be extracted
from the business and used as an
operational lifeline.
Beyond bank rationalization,
cloning presents additional treasury
challenges that can affect cash
forecasting, especially if there is
commingling of the sales or the
supply chain cashflows, foreign
exchange management processes,
and connectivity issues between ERP
systems and treasury workstations
with banking platforms. To overcome
these, treasury should engage its core
banking partners early to ensure a
seamless separation of the payments
and receivables flowing through the
correct bank accounts and avoid
reconciliation issues that can grow
exponentially if not resolved quickly.
Finding the right banking partner is key Companies that have been spun off are
under pressure to be up and running
quickly. They typically don’t have the
luxury of an extensive infrastructure
setup. That’s why treasury should
be looking for a banking partner
with proven large-scale corporate
restructuring experience to provide
support and advisory services. In many
cases, the bank will typically expand
its scope to offer service that goes
beyond business as usual. For this
reason, it is important to fully access
the bank’s liquidity management and
payments and receivables capabilities.
Treasury should be comfortable with
the bank’s ability to play a critical
role during the planning stages of a
spinoff and during the operational
setup, thereby providing treasury with
greater capacity.
Various regional and local regulations,
especially in emerging markets, may
prove difficult to navigate, which is
why selecting a bank with an extensive
global footprint is important.
1 From https://imaa-institute.org/statistics-mergers-acquisitions/, last accessed on 23 August 2016. 2 Source: Mergermarket and RR Donnelley. 3 From http://blogs.wsj.com/moneybeat/2016/05/17/company-spinoffs-look-like-a-win-win-deal/, last accessed on 23 August, 2016.
This makes a difference from a
centralization perspective and
because it can help avoid the need
to coordinate multiple banks and the
inefficiencies associated with a less
integrated overall solution.
In the case of Chemours, choosing
the ideal banking partner was critical
to achieving its strategic goals.
Citi was credited with helping the
company build a dynamic, holistic
cash management office, with a
near-real-time digital treasury.
Analytic insights that have resulted
from integrated KPI dashboards give
Chemours greater visibility into its
working capital positions across all
business units, helping decision-
making now and into the future.
Q. In terms of people, policies, processes and platforms, which ones should we be concerned with in times of a spinoff?
Q. Who should be our partners to help us be effective in managing a spinoff?
Q. What can we do to optimize our liquidity structure and improve working capital?
Q. While “cloning” or “lifting and shifting” to replicate treasury operations in a spinoff seems to be an easy decision, how else can we be more effective and efficient?
Q. When should we start to engage our banking partners?
Citi Perspectives | 51
Questions to ask banks:
Is cash still king?
52
INNOVATION SPOTLIGHT
A while back I came across an 1844 United States penny. It was solid copper and, at 11 grams, weighed more than three times today’s copper-plated zinc models. Imagine what it must have been like to carry around a pocketful of coins weighing 11 grams each.
52 | Treasury and Trade Solutions
Citi Perspectives | 53
Ron Tauscher Global Senior Product Manager, Receivables, Treasury and Trade Solutions, Citi
Drivers of cashless transactionsWhile faster in some countries than
in others, the move away from cash is
inevitable, and has been accelerating
in recent years. To understand why,
consider the forces propelling it.
First, cash is costly. Its cost, among
other things, puts a financial burden
on national economies. Currency has
to be manufactured, stored, moved,
managed, and insured, with significant
costs associated with each step.
According to recent studies by Tufts
University’s Fletcher School in the US
and Germany’s Steinbeis University
Research Center for Financial Services,
the cost of cash around the world
accounts for 1.5% of global GDP.2
Second, cash is risky. Cash is not only
costly to produce, move, and store, it is
exceedingly difficult to protect.
Unlike most cashless transactions
conducted by card, mobile phone, or
e-commerce, cash has no memory. As a
bearer-negotiated instrument, it bears
little data beyond the present holder of
the transaction. As a consequence, the
use of cash by companies small and large
has been subject to growing scrutiny.
Banking regulators worldwide continue to
press for strong anti-money-laundering
(AML) and know-your-customer (KYC)
procedures among financial institutions.
There is good reason for this. The use
of cash, while legal, can cause suspicion
owing to its status as a bearer-negotiable
instrument. The digital infrastructure
around e-commerce transactions, on the
other hand, deters money laundering.
Plus, the costs associated with electronic
payments are a fraction of those
associated with cash payments.
Today, 172 years after that coin went into circulation, cash continues to weigh down the pace and efficiency of worldwide commerce. In fact, cash still accounts for approximately 85% of consumer transactions globally.1 Cash remains particularly popular for low-to-moderate-value retail purchases and among the unbanked and underbanked, who in some cases, use cash purely out of necessity. Nevertheless, consumers and businesses today have more access to alternative payment methods than ever before and their preferences are changing.
54 | Treasury and Trade Solutions
Third, in many developed and rapidly developing parts
of the world, cash payments to businesses are becoming
increasingly inefficient. Studies by Visa show that
Americans, for instance, are two times more likely to carry
a mobile phone than cash. If you’re an American between
18 and 34, you are four times more likely.3
As the journey to cashless payment methods grows on a
global scale, some interesting oddities have emerged.
Thanks to Kenya’s M-Pesa mobile-money system, paying
for a taxi ride using your mobile phone is now as easy in
Nairobi as it is in New York. Nearly a decade after its launch
in 2007, the mobile payments platform has transformed
economic interaction in Kenya. In 2013, 43% of the
country’s GDP flowed through M-Pesa.4
M-Pesa’s success in Kenya illustrates how providers can
impact adoption of mobile money services around the world.
According to the Global Mobile Systems Association (GMSA),
in 2014 alone, more than 250 mobile money services were
operating across 89 countries. That figure includes more
than 60% of the world’s emerging economies.
Changing preferences and behaviorsAs the M-Pesa case illustrates, technology
developments and the security desires
of businesses and consumers alike are
shifting payment behaviors.
The dominance of cash is fading as
alternatives to cash payments continue
to grow rapidly in both developed and
developing markets. The most notable
of these include payments via mobile
devices, e-wallets, direct debits, and
bank transfers.
Businesses looking to migrate from
cash to electronic receivables should
consult experienced service providers
for assistance with cash-to-cashless
initiatives and determine the “must
haves” for their e-commerce solution.
Here are some things to consider:
1. KEEP IT SIMPLEWhile payment technologies and the
tools to initiate transactions are evolving,
electronic payments must remain simple
and accessible for consumers and
flexible for merchants. When evaluating
electronic payments providers, evaluate:
• The solutions they offer today, and
their plans for tomorrow.
• Plus the marketing tools they
deploy to help overcome barriers
to electronic payment adoption.
2. KEEP IT SECURESecurity is paramount. Any e-commerce
solution that is adopted must be agile
and resistant to a wide and growing
array of threats. No one wants to
experience identity theft or the
immense energy required to clear the
INNOVATION SPOTLIGHT
Citi Perspectives | 55
name and credit status of a payer. Trust,
confidence, and provider experience are
essential for any e-receivables system.
Therefore, it is critical to evaluate the
e-commerce and mobile payments
security initiatives that the provider
deploys today and plans to deploy
tomorrow, in addition to its anti-
money-laundering safeguards.
3. BUILD IT RIGHTEnsure that the e-payment
solutions being considered are
robust enough to handle huge
transaction loads. What’s more, the
processing technology must ensure
that transactions are fast, efficient,
and accurate. Every transaction,
regardless of size, should be
traceable and retrievable.
Businesses also need to consider
the region and country of their
payers. Offering a limited but locally
desirable payment method might
be the best solution for sending
the message, for example, that a
business is in touch with payers’
payment challenges and wants the
payment process to be accessible
and simple.
Ask providers about:
• Their track record of successful
e-receivables systems
implementations.
• The scope and strength of their
local, regional, and global reach.
• And their transaction reporting
offerings and capabilities.
ConclusionCash as a payment instrument is in decline, and it has some
time to go before it will be insignificant. What is of increasing
significance, however, is the expense to monitor, manage, and
protect cash as a payment instrument.
Regional demographics and payment behaviors, along with
easy access to e-commerce tools, are driving e-commerce
solutions from emerging to ordinary. While moving at different
speeds in different developed and developing markets,
e-payments are quickly taking flight on a global scale.
Electronic payment alternatives, which are significantly
cheaper to process than cash or checks, are becoming
virtually ubiquitous.
Having an experienced banking partner, who can address
specific business and marketplace needs, is key to making the
right choices today for a more successful cashless receivables
portfolio tomorrow. The time to prepare for the increasing
adoption of electronic payments transactions is now.
1 Measuring Progress Toward a Cashless Society, MasterCard Advisors, accessible at http://www.mastercardadvisors.com/_assets/pdf/MasterCardAdvisors-CashlessSociety.pdf, last accessed on 16 August 2016. 2 Source: See MasterCard Advisors. 3 Source: “Cash is Trash: The Future of Mobile Payment,” September 2014, available at http://www.forbes.com/sites/techonomy/2014/01/23/cash-is-trash-the-future-of-mobile-payment/#62ec2f062e1c, last accessed on 16 August 2016. 4 M-Pesa and the Rise of the Global Mobile Money Market,” 12 August 2015, available at http://www.forbes.com/sites/danielrunde/2015/08/12/m-pesa-and-the-rise-of-the-global-mobile-money-market/#1aae87c023f5, last accessed on 16 August 2016.
Global tax initiatives: the evolving regulatory environment
56
GLOBAL TRENDS
56 | Treasury and Trade Solutions
Citi Perspectives | 57
Dan Stern Global Head, Governance and Risk, Liquidity Management Services,Treasury and Trade Solutions, Citi
Beginning with the Foreign Account Tax Compliance Act (FATCA), governments around the world have been working towards automatic exchange of information between tax authorities in an effort to curb tax evasion and promote transparency. Since 2010, more than 100 countries have made changes to their rules on information reporting, with more on the horizon, which is putting increased pressure on financial intermediaries to take a more active approach to ensure they are prepared to comply.
Unfortunately, as global, regional,
and local banks enhance their due
diligence procedures to meet these
new requirements, corporates
find themselves facing differing
documentation standards due to
differences in local law requirements.
This may result in the collection of
multiple tax forms from a single entity
to satisfy various tax initiatives.
The three tax initiatives that are
affecting corporates and banks
today are: the Foreign Account Tax
Compliance Act (FATCA); the Common
Reporting Standard (CRS), and the
United Kingdom Crown Dependencies
and Overseas Territories (UK CDOT)
which will be replaced with CRS. The
balance of this article will give an
overview of these regulations with the
goal of helping corporates understand
how banks are approaching them, and
what corporates will be required to do
to stay in compliance.
The implications of information reporting and tax-withholding requirements FATCA, which is US tax legislation, is
aimed at preventing or detecting tax
evasion by US taxpayers who maintain
financial accounts outside the US or
who invest offshore through non-
US entities. FATCA requires that for
accounts opened prior to January 1,
2015 banks must search for indicators
of US status. Both US financial
institutions and participating non-US
financial institutions must request
58 | Treasury and Trade Solutions
documentation to establish the FATCA
status of all account holders.
Corporate accounts opened on or after
January 1, 2015 require the collection
of documentation that establishes
FATCA status period. In addition,
financial institutions must identify any
US indicia that would require further
documentation. Banks must validate
tax documentation collected against
all current account information.
They must also monitor all accounts
for changes in circumstances that
might affect the FATCA status of the
account holder and collect additional
documentation, as required.
In addition, FATCA requires that
financial institutions holding
US accounts or undocumented
accounts outside the US report
certain information regarding these
accounts directly to the Internal
Revenue Service (IRS) or to local tax
authorities for exchange with the US.
Beginning January 2017, US source
income subject to withholding is
expanded to include bank deposit
interest paid by a foreign branch of
a US bank. Therefore, if a corporate is
not properly documented, interest
paid by a branch of a US bank will be
subject to US withholding tax.
To determine the reporting obligations
for an account opened prior to
January 1, 2015 (pre-existing account),
banks were obligated to perform
outreach by June 30, 2016, and many
continue the process of working with
clients around the world to request
necessary information. Corporates can
be prepared by taking steps, such as:
• Identifying legal entities that do
business with all banks.
• Contacting a trusted banking
partner to help better understand
the specific requirements.
• Engaging your tax department to
explain the regulations and the need to
prepare tax forms that will be required.
• Taking advantage of online tools
designed to help navigate the
compliance process. Citi offers tools
and simplified instructions to help
clients complete forms and avoid
common errors. This is particularly
helpful in avoiding one of the most
frequent: using the wrong tax
forms. (See: https://www.citi.com/
tts/sa/taxinitiatives/fatca.html.)
Meeting CRS and UK CDOT requirements Similar to FATCA, UK CDOT requires
financial institutions in the U.K. Crown
Dependencies to identify UK residents;
UK CDOT applies to new accounts
opened on or after July 1, 2014. UK
CDOT will be replaced with CRS.
CRS, which went into effect on
January 1, 2016 for approximately
50 early adopting jurisdictions,
expands the automatic exchange of
information to require the collection
of tax residency information and
exchange such information with
those participating jurisdictions. This
regulation requires the collection
of documentation to establish the
country of incorporation for new
accounts and information for tax
residency for such accounts.
Citi Perspectives | 59
In addition, similar to FATCA, financial
institutions need to make sure there
is no inconsistent tax indicia in its file
regarding a taxpayer’s claim of tax
residency. Also, there is a requirement
to solicit CRS documentation for pre-
existing accounts.
Under CRS, corporates opening cash
accounts in participating markets, or
in time deposit, minimum maturity
time deposit (MMTD), or similar
interest-bearing instruments, which are
considered financial accounts, will have
to provide a CRS self-certification form.
Financial institutions doing business
in CRS participating jurisdictions will
be required to report certain account
information of their clients to all
participating CRS jurisdictions in 2017.
The upshot is that corporates need to
be aware of these requirements and
make sure they are in compliance.
Since 2014, more than 100 countries have made changes to their rules on information reporting, with more on the horizon.
Meanwhile, Citi is working hard to
reduce the volume of documentation
that corporates are required to provide
to stay in compliance with UK CDOT
and CRS by leveraging overlapping
information whenever possible.
Staying on top of the changing tax landscape Staying on top of the changing tax
compliance landscape is no easy task.
Local governments are continuing
to issue new directives. Over 100
jurisdictions have committed to
adopting CRS between 2016 and 2019
and we are awaiting local guidance
from many of these jurisdictions.
Citi is diligently working to understand
the implications of these initiatives,
while keeping the client experience in
mind. We are always looking for ways
to streamline the process.
© 2016 Citibank, N.A. All rights reserved. Citi and Arc Design is a registered service mark of Citigroup Inc.
Citi Online AcademyOur Commitment to Learning. New Ways of Bringing It to You.
At Citi, our Online Academy is committed to helping further your success. Our industry-leading experts conduct a wide range of customized, interactive webinars — spanning today’s critical and complex subjects.
For the schedule of our upcoming “anytime, anywhere” programs, to enroll or to suggest a topic for future sessions, please visit us at citi.com/onlineacademy.
Fortunately, we saved you a seat.
Citi PERSPECTIVES
Citi Perspectives | Autumn 2016
04 Perspectives for 2017: creating optionalityA look ahead to 2017 as treasury teams plan for new challenges
14 Brexit: the effect on corporatesAn assessment on the potential impact on different corporate sectors
Cybersecurity: the impact to the financial supply chainAn overview of the effect of cybercrime on the business and banking community
36
Treasury and Trade Solutions transactionservices.citi.com
© 2016 Citibank, N.A. All rights reserved. Citi and Arc Design, CitiConnect and CitiDirect are trademarks and service marks of Citigroup Inc. or its affiliates, used and registered throughout the world. The information and materials contained in these pages, and the terms, conditions, and descriptions that appear, are subject to change. The information contained in these pages is not intended as legal or tax advice and we advise our readers to contact their own advisers. Not all products and services are available in all geographic areas. Your eligibility for particular products and services is subject to final determination by Citi and/or its affiliates. Any unauthorized use, duplication or disclosure is prohibited by law and may result in prosecution. Citibank, N.A. is incorporated with limited liability under the National Bank Act of the U.S.A. and has its head office at 399 Park Avenue, New York, NY 10043, U.S.A. Citibank, N.A. London branch is registered in the UK at Citigroup Centre, Canada Square, Canary Wharf, London E14 5LB, under No. BR001018, and is authorized and regulated by the Financial Services Authority. VAT No. GB 429 6256 29. Ultimately owned by Citi Inc., New York, U.S.A.
These materials are provided for educational and illustrative purposes only and not as a solicitation by Citi for any particular product or service. Furthermore, although the information contained herein is believed to be reliable, it does not constitute legal, investment or accounting advice and Citi makes no representation or warranty as to the accuracy or completeness of any information contained herein or otherwise provided by it.
GRA27448 09/16