It is a fact that since the last financial crisis, the complexity and number of banking regulations have increased dramatically. CRS, EMIR, FATCA, MIFID. All these acronyms are familiar for those working in the financial industry as these regulations affect all departments of banks, one way or another.

New regulations require adaptation of internal processes. However, adapting without seeing the big picture, will lead to implementing one patch on top of another, potentially missing an opportunity to re-think processes. Moreover, new regulations often lead to new compliance risks, if the regulatory requirements are not embedded across an organization. Therefore, it is key to ensure that each employee has an understanding, aligned with his or her role and responsibility, of the regulatory framework surrounding him/her. This is not only necessary, this is mandatory. Indeed, regulators often consider training to be a key element of compliance. For example, with respect to FATCA, part of the FINMA-required regulatory review for 2016 will look into the training of banks’ employees.

Smart training is not about “ticking the training box”, it is about adding value, increasing efficiency and reducing risk by tailoring the training to the audience. It goes without saying that compliance officers must have in-depth knowledge of regulations, however, a bank cannot rely only on its compliance officers to be the single gatekeepers. Each and everyone has a role to play when it comes to compliance. Put simply, each and every employee needs suitable training.

This is especially relevant for relationship managers (RMs). When it comes to FATCA and the Common Reporting Standard (CRS), RMs play an instrumental role in client due diligence requirements. These regulations require the re-documentation of clients with specific new forms. The position of RMs on the front line makes them key building blocks in FATCA and CRS compliance. It is also expected that RMs remain vigilant to identify whether client provided information is aligned with information already in a bank’s files. In addition, as the primary client contact, client questions will first be addressed to RMs. Even though the content of these forms may be technical, RMs must be able to answer basic questions, explain why information is required and the consequences of providing (or not providing it). However, this cannot be achieved without the RM possessing an understanding of the topics. More importantly, if RMs are not able to answer those questions, RMs will need ongoing assistance to accomplish daily work leading to either a need to increase the size of support teams, which comes with a cost, or a delay in handling client-related requests.

In other words, today’s new regulatory framework requires financial institutions to invest in human capital, in the technical training of employees in order to remain competitive and to maintain the highest standard of client service.

Brandi Caruso, Director, Financial Services

Brandi is responsible for FATCA in Switzerland and leads a cross-functional team, including projects for banks, trust companies, asset managers and insurers. She is a FATCA technical advisor to a number of large and mid-size Swiss banks, Swiss-based trust companies, asset managers and insurance companies. She is a U.S. Certified Public Accountant and has 15 years of experience with Deloitte in the U.S., the U.K. and in Switzerland.

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Karim Schubiger, Senior Manager, Financial Services

Karim oversees FATCA and CRS engagements in the Suisse Romande and Ticino markets providing advice to financial institutions, such as banks, trustees and insurance companies. Karim has an international tax law as well as an engineering degree. He has more than 11 years of experience in the financial industry, including eight years working in banks in Switzerland.

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