CPC-TDS Phase 2

Phase 2

Planning &

Design of CPC

TDS

Presented by: CPC TDS,

Directorate of Systems, CBDT

Presentation for: BCAS, Mumbai

Date: 23rd Jan. 2019

01Brief Overview of CPC TDS (Existing Phase 1)

02Performance Measurement of CPC TDS- Indicators

03

Why the need of Phase 2- Problem statement, Response to it, Specific Issues/ Areas Addressed

Scheme of Presentation

04Key Innovations Planned in Critical Services of Phase 2

05TRACES and AO Portal

Brief Overview of CPC TDS

(Existing Phase 1)

Key functions performed by CPC TDS are:

– 26AS for every taxpayer showing all TDS and taxes to their credit,

– Automated SMSes for TDS deductions of salaried taxpayers,

– Electronic filing of TDS Statements,

– Electronic Communication to Deductors and Taxpayers,

– Seamless, state-of-art Grievance Management System & Call Center

– Online Contactless system for Lower/ Nil TDS Deduction Certificate u/s 197.

– Capacity Building & Corporate connect

– National Award for e-Governance- Gold Award in 14-15

– PM Award for Excellence in Public Administration in 12-13

Why the Need of Phase 2-

Problem Statement

– 1. Compliance/ enforcement/ evasion- ITD

– 2. Services -TPS- taxpayer, deductors, AOs

– 3. Ignorance/ incapacity of taxpayers and AOs

– 4. Limitations of TDS compliance platform- Technology as well as law

– 5. Technology refresh- due to emerging technology and obsolescence

Why the Need of Phase 2-

Solution statement (Approach)

– 1. Research, envisioning & Preparing a Roadmap for 10 years (Jan.- May ’17)

– 2. Stakeholder Consultation

– Taxpayers, Deductors, Professional Bodies, OEMs, AOs, ITD, Inter-Module & Inter-

Department consultations

– 3. SAINTS Approach

– 4. Planning & Design and Brainstorming with Consultants

– 5. Industry Consultations

Why the Need of Phase 2-

Specific Issues/ Areas Addressed

– KMS- For Training & Capacity building

– Emerging tech

– End to end automation

– LMS

– Business intelligence- enforcement and fraud prevention

– Natural systems and continuous or running ledger

Why the Need of Phase 2-

Specific Issues/ Areas Addressed …Contd.

– Passbook system for fungibility in TDS payments

– AI and cognitive computing- fraud prevention, taxpayer services (virtual assistants), automation of services and processes

– Omni channel two way communication- mobile app, email, call, document, sms, chat apps & social networks

– Grievance redressal and dispute resolution- including appeals- automation & Accuracy

– Dynamic TDS rates under s. 197

– Integrations with other partners for validation/ confirmation/ data exchange of transactions- GSTN, MCA, stock exchanges, NSDL, banks, financial institutions, regulators and commissioners and registrars of statutory or government bodies.

S A I N T S

AutomatedIntuitive/

Instantaneous

Symbiotic Transactional

NaturalSeamless

Key Innovations Planned in Critical Services of Phase 2

API & Blockchain based, GST like Real-time Deductee Row wise

filing of TDS deductions

Instead of all TDS transactions for 3 months being filed together,

each TDS deduction to be transmitted individually as an

independent file (3 month, or any period option also available)

All such individual deductee rows to be compiled in a continuous

ledger for the Deductor

The deductee row details to be prepared and transmitted

automatically from Deductor to CPC TDS immediately after entry

in Books of Accounts of Deductors, using Natural Systems and

Blockchain based APIs

Intimations to deductees for such deductions to go on a near

realtime basis- choice of apps, emails, SMSes and personalised

dashboards for taxpayers

Facility for deductees to raise objections directly from their inbox

Existing and New Systems to run in parallel; transition & change

management

Passbook System for TDS paid by Deductors with

electronic credit for all TDS in their dashboard

Deductors can modify or allocate any amount from

Passbook to a deductee row or a set of rows by

querying/calling for available credit amounts (TDS in

passbook) deposited within a period of time or date

Locking of TDS credit with liability and subsequent

freezing to kick in after that; to check frauds

State-of -Art Call Centre & Ticket Management System

• AI based Virtual Assistants

• Omni-Channel communication- Paper, email, Call,

SMS, Mobile App

• Personalized Dashboards for all Stakeholders

• Real-time, automated online mismatch removal system

Online Appellate Process

Proposed improvements in

Business Processes and Interaction Platforms

(D= Deductor, Business Enterprise; d= Deductee, taxpayer; CPC= Income Tax Department)

TDS Statement Filing – Natural Systems

Deductor

Deductee

CPC TDSProcessing- Credit vs

Debit

Financial Institutions

(Banks)

#2.1 ITNS 281

#2.2 CIN

#2.0DD TDSLeger

Account APIIntegrationWith CPC

(Natural Systems)

#2.2.1 Link CIN to TDS Ledger

OLTAS

#2.3

#2.4 Tax Deposit Details Credited to

respective Deductor s Passbook

Deductor Passbok

#2.5 Tagging of dd rows against challan

Locking-Matching Of available Challans (Via algorithms of FIFO & Closest Match) for Demand Amount Generated Post Processing

Deductee Dashboard

#2.6.1dd validates

TDS or Raises

Grievance

#2.6.2

1st Level of Grievance :DD – dddd raises grievance

for any deemed TDS/TCS deduction

DD-dd & Respective Banks on Blockchain for

Dispute Resolution

Ticket Management System

#2.6.32nd Level of Grievance

to AO :DD-dd

dd raises unresolved issues

TDS-AO

#2.6.3.1

2nd level grievance escalation

#3.0 Demand u/s 200A

Demand against 201 or 201(1A)

#3.1 2nd Level of Grievance:DD – dd

Unresolved issues ->AO

#1.0 DD deducts TDS/TCS

11

Function/ Service Flow of data exchange Variabilities

TDS Statement D CPC All form types – Including 26QB, 26QC etc.

Processing Results CPC D Demand/ Default/ 26AS

Correction D CPC Row wise correction statement

Correction Results CPC D Demand/ Default/ 26AS

Consent Mechanism with deductee & Dispute

Resolution

DCPCd Functionality for d to validate his TDS/TCS

For disaccord d to raise grievance for correction on CPC ecosystem

2nd level Grievance handling CPC

12BB for Salaried d D CPC Secure & Encrypted Library of Investment Proofs of d with CPC

Annexure II populated -> CPC

197/195 – LDC/NDC dCPCD LDC on TRACES

Distribution of LDC Amount

LDC Tax Master Update

15 G/H Compliance dCPCD Validation for Threshold of 15 G/H

26AS CPC d, CPC D Seamless 26AS Credit -> Real time Processing

Exchanges Through Natural Systems

Reconciliation Book

Solution - Reconciliation Book

Adjustments Reason Such as : M&A, Liquidation, LH, RA

Adjustments Needed Between:

----------------------------------------------------------------------BoA of Deductor TDS Statement

API File Format i.e. Deductor’s ledger Account format to be in sync and tandem with ITD [CPC

(TDS)] current or proposed simplified TDS/TCS form for filling of applicable TDS/TCS statements.

Every Deductee Row to have an optionality to be seamlessly filed

Conversely, Deductor can send his/her Statement rows at his deemed suitability to CPC TDS

for processing with End of Quarter as a deadline

Failing which transactions sent for processing after applicable timelines will initiate default

generation.

Correction Filing -> Subsequent to default/demand Generation or at his/her deemed situation

The processing results will be transmitted back into designed ledger accounts in the

accounting software of the deductor so that the deductor have the latest and real-time

processing results

The TDS/TCS deduction statements will be processed and accounted for on a row-to-row basis

instead of a batch of rows

All such rows will be prepared, processed and stored in a continuous ledger.

Automate

Natural Systems

Considerations

Challan Payment and Credit of TDS – Proposed Passbook System

Matching of TDS liability u/s 200A with credits in

Passbook (w.r.t Ch. 281)

TDS liability determinedu/s 200A(CPC-TDS)

Processing

Passbook

OLTAS

Banks

Pay any lump- sump challan on running basis

Pay Corresponding Challan

Submit TDS Statements(with or w/o CIN No.)

Prepare TDS Statements

Deductor s Dashboard for Matching and Locking Payments

dd row |date of liability | liability u/s 200A Matching credits from passbook (281) Date of credit in passbook Lock Fetch passbook credits

Matched by automated algorithm or by CIN provided along with TDS statement

Use Algorithm Use CIN Manual Match

(Optional)

Mention CIN No. Or

ALL

15

Challan Payment and Credit of TDS - Passbook System

No linking or interlocking of challan (payment) with TDS deductors (statement) required untila. After the processing of TDS deductors (statement) u/s 200Ab. Challan (payment) credit is available in OLTAS

Automated algorithm will then match and link (pre-tagging) the TDS deduction (statement) with the right challan.

Deductors can override such automated pre-tagging and reallocate/ re-tag the credit

All TDS Payments to appear as credit in a sort of a passbook – Any sum up to 1 Rupee can be tagged with any statement (Deducted Row)

Deductor can modify or allocate any amount from Passbook to a deductee row or a set of rows by querying/calling for available credit amounts (TDS in passbook) deposited within a period of time or on a particular date

Once such tagging is submitted by deductor, the payments will be finally locked with TDS deductors/ statements.

Once the credits are locked, the rules of freezing and unfreezing shall apply

1

2

3

4

5

6

7

Impact of Natural Systems and Passbook System

Transactionalization of deductee rows

• Each deductee row to be a TDS statement in itself

Ledgerization of deductee rows- Running or Continuous Ledger

• Deductee rows can be pulled & processed together or singly for any period

Passbooking of payments and then locking the credit amounts in Passbook with liability w.r.t each deductee row;

• To be done in automated manner for best fit after considering time & Interest impact

• Deductor to have overriding power to change automated linking

• Once locked, the rules of freezing & unfreezing to apply

Grievance Redressal / Dispute Resolution - 26AS / Inbox - Transactional

CPC-TDS

DD

CPC-TDS

OLTAS

Bank

Grievance

Agreed#2.1

Agreement Correction#2.2.1

#2.2.2

Not Agreed

DD Bank

#2.3

#2.3.1Disagreement

received from DD

Agreed#2.5

Not Agreed

DD Bank

#2.6

#2.6.1

DD BANK dd Bank

Smart Contract

#2.7

Decision#2.7.1

#2.7.1.1

#2.7.1.2

Indecision AO#2.8

Decision

#2.9

#2.9.1

#2.9.2

Disagreement from DD + dd Bank

#2.6.2

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Processing dd 26AS Credit

Message of Payment

DD Passbook

dd

Intimation/ Messaging of

deduction

Processing of

Deduction

Benefits of Phase 2# What we plan to achieve! How?

1 Original statement e-filing on Traces Enhanced Traces Portal functionality

2 Real time statement filing Natural Systems

3 Reduced instances for corrections Natural Systems

4 Effective notifications to DD and dd Personalized Dashboard/ Ledger

5 Near real time statement processing Natural Systems

6 Effective and transparent dispute resolution Blockchain

7 • Proactive problem management• Effective grievance management

• Helpdesk tool, KMS and service management team• Artificial Intelligence enabled Virtual Assistants

8 Preempt potential tax evasion cases Business intelligence enabled fraud framework

9 Taxpayer Profiling to prevent tax frauds Business intelligence enabled fraud framework

10 Trust worthiness across the TDS ecosystem Blockchain enabled transactions for 15G/H, 197, 26AS etc.

11 Dedicated learning and training platforms Enterprise grade LMS platform and dedicated training environment in sync with production

12 Uniform/ standardized experiences Dynamic rule engine and BPM enabled system workflows reducing human interfaces

13 Effective infra utilization On premise private cloud setup

14 Seamless integration with interfaces API enabled TDS services

15 Additional scope • 3rd party data collection and verification for 12BB Annexure 2 24QPrefilled ITRs

• Equalization levy to STT, DDT, CTT

Exponential Technologies – Proposed Use Cases in CPC TDS

01

Form 15G/15H

0226AS Data

Validation for Banks

03Collaboration with Banks for

Recovery

04Sharing of Ledger accounts & other

details

Calculation of Cumulative income in real time before accepting 15G/H

Trustworthy verification mechanism for Banking System for ascertaining creditworthiness of loan applicants

Common pooling of Tax Demands and Bank loans & Collaterals to restrain and prevent default(ers)

Centralized Electronic furnishing of Ledger accounts & other documents by taxpayers and Banks based on requisitions/ notices by AOs.

02Text here

02Chatbot –Virtual

Assistant

03

Text here

03

Text here

03Business Process

Monitoring

04Automated 197

NDC/LDC

Data Analytics based on taxpayer profile, financial results, & regulatory bodies’ data to identify & act on potential Tax Evaders

The queries of taxpayers to be answered by AI based virtual assistants, which will have algorithms trained on available literature

Proactive monitoring for real time detection of potential disruptions & preventive action for mitigating the disruptions- Tax Frauds

To make 100% system based decision-making to issue lower/NIL deduction certificates of TDS to deductees.

01Taxpayer / Deductor

Profiling

05197 NDC/LDC

Taxpayers can obtain LDC/NDC without quoting their Deductors; they will be free to allocate amounts to Deductors of their choice later

05Automated Complaint

Management

Upon receiving a grievance, the system will provide the proposed resolution process at run time ; re-route tickets based on past history

Blockchain Artificial Intelligence/Machine Learning

20NATURAL SYSTEMS

Lower Deduction Certificate – u/s 197, 195(2), 195(3)

Current Process

01

02

03

04

At present, the FILING PROCESS is MANUAL in mostof the Pr. CCIT Regions

The processing by the concerned AO TDS is a completely manual process, which involves physical hearings and

submissions

The award of No/LDC and its subsequent accounting in thededuction process by Deductor and processing by CPC TDS

is accomplished through a mix of manual and semi-automated processes

As a result, both the taxpayers, Deductors and FAO have to go through a no. of steps in managing & discharging

their respective obligations

System based partial decision making01

90% automated decisions02

• Automated decision making in 90% of cases based on formula used in Phase 1

• No discretion of AO 100% system based decision03

To automate the decision-making and eliminate discretion or subjectivity associated

Income % to be determined on extrapolation basis

Rate may be determined on section type and throughput of business

LDC rate may be specific to each dd, who in turn can distribute this finite/ infinite amount to DD

TDS tax master to show LDC rate for dd-DD combination

Three Stages in automation of LDC/ NDC

System based partial decision making01010101

• System calculates and provides to the AO the extrapolated lower/ nil TDS rates (LDC/ NDC) based on past trends & pending demands,

• Completely online & Contactless

System based partial decision making01

Flow depiction of LDC u/s 197

PAN & TAN details

Ask rate

Estimated Income

Section code

dd: deductee

Documents to be

submitted

TRACES

By Assessing Officer:

to be processed in

30 days

#1.1

CPC ITR: E-filing

Data Inwarding such as

last ITR challan,

Previous demand, etc.

AI tools & Rule based engine

for automatic assessment of

LDC rates

2nd

level assessment by

JCIT

#1.3

#1.2

3rd level assessment by

CIT

>=50L INR

#2.1 LDC

Certificate

DD: Deductor#3 Form 13 (Rule 28AA)

TDS LDC Certificate

CPC-TDS

Statement Filing

#4 Natural Systems

#4.1

In case of Short

Deduction,

default will be

intimated

#5 LDC Certificate on 197

Tax Rate Master

#1

Business Intelligence (BI) & Management Information System (MIS)

Predictive & Interactive Data Analysis and

Reporting

Flexible format reports with multiple ‘Slice & Dice’ options. Customized Queries with Voice to text option

AI and Advanced Analytics enabled solutions for Pro

Active Compliance

Risk Profiling and Prioritization Matrix using

multiple data resources

BI & MIS

Performance and trend analysis in customizable time period with graphical and tabular datavisualization

Learning & Knowledge Management System

Content

Ease of use - for user with limited

computer knowledge

also

E-learning content for all the stakeholders

throughout the year

Content development to

be dynamic and role

based

Modules shall contain simple

description & explanations

with hyperlinked details,

videos etc.

360 degree learning

Ability to search and

recommend across content,

pages & courses

AI Capability based platform

Lessons to be highly interactive

and intuitive (audio & text

based help sections)

Integration with the content for step by step

guidance

Dynamic &

Role Based

Interactive Voice Features

Interactive & Intuitive

Test Environment

Role based

Tests.

Easy to Use and Seamless Experience.

Dummy Data Statement Processing

Real Time Learning

Errors course material study & Recommendation

Simulated Practice Comprehensive learning

• Testing/dummy environment for Deductors and

other stakeholders of CPC-TDS.

• Replica of production without data

• To provide sample tests with the dataset and

provide processing results.

Simulated Practice Comprehensive learning

Simulated Practice Comprehensive learning

Virtual Assistants - Providing TDS/TCS statement processing status, refund

status to the tax payer

CHATBOTS – Basic Queries, FAQs, later to be matured

Self Learning (AI/ML)

Robotic Process Automation of Bulk Functions

Enhance scalability, performance & responsiveness

Timely Resolution of All Service Requests

Unified Call Center of ITD

Click to Call, Text to Speech and Speech to Text for ease of recording, storing, & analyzing

Quality monitoring solutions

Voice Biometric with NLP for user’s identification and faster response time.

NLP to understand heaps of unstructured voice call data, emails, communications

One CentralSolution

State of the Art Customer Care Call Centre

Customer

IVR

Automated Status Status of Report Default Clarification Portal Help Grievance 26AS Issues Speak to Agent

text

CC Supervisors (Support)

TRACES TMSResponse

through CC Agent/Email

PA Team ITD Tech Team

Call Center Work Flow

Chatbot Natural Language Processing

Extracted user s intent and entities from the phrase

Trai

ning

Fee

dbac

k

Chatbot Packages response into proper format for display

Call Center Workflow

• Create an overall digital marketing strategy for building awareness and promoting services

• Develop campaign content targeting all types of taxpayers.

• Develop a media plan covering all the effective channels of digital communication to disseminate all campaigns.

• Outreach and Content on various vernacular languages.

• Analytics and heat maps to understand challenges faced by users in navigating the website and to optimize user experience

• Continuously measure the performance of the campaigns on key metrics and take appropriate measures to optimize campaign effectiveness.

Mass Outreach

Collaboration

Dynamic Content

Analytics & KPI

Social Media Outreach

TDS / TCS Calculator on TRACES & Mobile AppAnd Functionality to

provide flexible dashboard to website users.

Display a running ledger account of every deductor in his dashboard showing all debits and credits of all TDS/TCS paid

Challan generation functionality via TRACES portal

Enable MIS Reports and lookup facilities for all users

as per roles and responsibility

TRACES Online Filing and Uploading of Original TDS/TCS statements on TRACES in enhanced conventional systems

TRACES 2.0 & Taxpayer Mobile App

Audit reports

Functionalities Virtual assistant

Interactive dashboards

(Personalise)

AO Registration

Demand transactions

(Resolution of Double Demand)

a. MIS dashboard with analytical tools to compare past year performance & industry trends.b. Creation of sub-user for all users c. Transliteration software d. Calculator for compounding/demande. Real-time PAN demand view f. e-attachments

Functionalities

AO to upload the transactions based onwhich any demand outside system can becalculated & be raised in the system itself.E.g. Demand by order u/s 201 after surveyetc. The transactions can be used asstatement/partial statement.

Demand Transactions

Registration of new officers on TRACES through request initiated by RCC without any manual intervention

AO Registration

AO Portal

a. Audit reports visibility to AO on AO Portal and users data to be leveraged from CPC ITR

Audit reports of PAN

a. To help user browsing the portalb. To pull out customized reports using NLP/voice to text as required and backed by AI enginec. User can be prompted to answer queries such as whether the info was useful or not

Virtual assistant

a. Should include actionable items such as Prosecution, penalties & refund etc.b. View only items such as reports (under jurisdiction) & analytical toolsc. Training tutorials

Interactive dashboards

AO Portal

Demand Resolution

Solution:

• AO demand to be treated as TDS Statement (Change in Legal Framework)

• Functionality of re-conciliation process (not at rows but as gross level ) between deductorversion and AO version

• Subsequent to reconciliation, functionality for addition, modification, and deletion

• AO can further raise demand

Duplication of Demand ->AO raises a demand andDeductor files a TDSstatement

Manual Demand duplicated after filing of TDS Statements

AO Portal Overview

FAOGrievance Functionalities

KnowledgeManagement

SystemProsecution

Penalty

Refund

Corrections, Challans,

etc.

BI/ MIS Recovery

Survey

Helpdesk

Multichannel Communication (Call,

Email, etc.)

Mobile Application

- Seamless Integration with CPC TDS 2.0 Portal and communication and information sharing capabilities

Seamless Integration

01- Interactive helpdesk features such as AI based Virtual Assistant, individual chat agents and option to reach out to call center agents to be extended to app.

Helpdesk

02

- Best In Industry Security Features. Timely and Comprehensive Security Audits and Compliance.

Security

03

- Pop-up links to all tutorials, e-learns, FAQs, links to social media contents, and Learning Managements System. Interactive &

Transactional

04

- Raise and track grievance and service requests tickets from deductor’s or deductee’s Dashboard

Grievance Handling

05

CsITAppellant

TEMPLATIZATION

of CIT Appeals

Simplificati

on of CIT

Appeal

Process

Faster

Resolution

of Appeals

Streamlined

Processes

Functionality

on

Deductor’s

Dashboard /

TRACES

CIT (A)

Appellate process

over NS –functionality to upload/

send the supporting

artefacts

CIT (A) Mechanism

Deductor

Notices + Documents + Ledgers, etc.

Can be called for over Natural Systems

CPC=TDS

Details + Documents needed

A predefined list from which CIT(A) can choose

FAO(TAN)

Aby order, notice or decision, that is not there with CPC-TDS

FAO(PAN)

CPC-TDS will fetch information/docs./confirmation pertaining to AO PAN from CPC-ITR, E-filing, ITBA, and or ITD/Data warehouse

Just like 197 process

Use

rsTo

uch

Po

ints

Co

mm

un

icat

ion

Ch

ann

els

Acc

ess

&

Au

then

tica

tio

n

IT Users IT UsersAdmins

Mobile Application

Call Centers3rd Party Application Portals

SMS Email Mobile App Notifications

Dashboards Outbound Calls

Authentication & Authorization Management

Biometric/ Token/ DSC Authentication

Roles & Profiles Service Single Sign On Setup Auth Rule Store

IT Users Support UsersIT UsersDeductorsIT UsersProfessionals IT UsersIT UsersTaxpayers TDS AOs 3rd Party Users

TDS Stakeholders Communication and Authentications Channels

CPC-TDS 2.0 Functional Architecture

New Functionality

Old CPC-TDS Functionality

Old CPC-TDS Enhanced Functionality

CPC-TDS Processing

Pre

-Pro

cess

ing

Pre-population of statementsStatement Validation

Statement Filing

Statement Generation

Data Inwarding

OLTAS/ TIN- FC Matching

Taxpayer intimation for pre-populated statements

Scanning and Data Digitization

Data interchange and validation

Inbound mails

Legend

Pro

cess

ing

Form 26AS Credit OLTAS Challan Matching

Seamless API Integration (Near Real Time Processing)

AO Assessment survey

Row wise processing

Tax & Interest computation

Accounting Rule EngineValidations &

Batches

DMS (Inbound and Outbound)

Demand computation & management

Default Computation

Business rule Engine

Natu

ral Systems

Manpower Requirement

MIS/ BI

Po

st-P

roce

ssin

g

Integrated Communication Orders & Appeals

Rectification

Refund managementAO Call Center

Customer Care call center

Improvised IVRS

Stuffing & Mail

Correction filing

TMS

Automated Dispute/ Grievance Handling

Exponential Technologies

Smart Contracts for Dispute Management

Data Sharing over Blockchain

BPM Enabled process workflows

BI Driven Fraud Framework

AI/ML enabled Virtual Assistants

SLA Monitoring

SLA Monitoring System

Performance Audit & Analysis

Record Management

Others

TDS Forms/ Challans

TAN Allotment

TRACES & Taxpayer Mobile App

Interactive User Dashboard

Original e-Filing

Challan Generation Facility

Passbook System for Accounting

TDS/ TCS Calculator

Performance Tuning of System

Dynamic and customizable MIS reports

AO Portal & Mobile APP, Demand Management, Tax

Payer Facilitation

Demand Management

TAN/ PAN Audit Reports to AO

Tracking and Monitoring

Case Management

Partner Ecosystem

Personalized Dashboards

Omni-Channel Communication

Mismatch Resolution

Stakeholders Engagement

Learning Management System (Dummy Environment)

Outreach Activities

Call Center

Interactive Dashboard

E- Modules (filing, grievance appeal, etc.)

Campaign for Demand

Taxpayer Education

Future Taxpayer Outreach

Timely & accurate TDS/TCS filing

Promotion of Emerging Tech.

From Retrospective to Proactive Compliance

Campaign Management

Thank You!

39