2023-01-17-安永-8_areas_of_change_for_financial_services_regulatory_policy_in_2023_13页_13mb

报告摘要

2023 Global Financial Services Regulatory Outlook Summary

Core Content

The 2023 Global Financial Services Regulatory Outlook outlines the evolving regulatory landscape for financial institutions, emphasizing the interplay of geopolitical tensions, economic instability, digital transformation, and ESG (Environmental, Social, and Governance) considerations. It highlights the need for firms to anticipate and adapt to regulatory changes to maintain operational resilience and competitive advantage.

Main Views and Key Information

1. Geopolitics and Regulatory Fragmentation

Global Tensions: Geopolitical risks, especially the war in Ukraine and US-China tensions, have intensified regulatory divergence.
Regulatory Autonomy: Jurisdictions are increasingly influenced by political and strategic autonomy, leading to fragmented regulatory approaches.
Impact on Firms: Financial institutions must now consider legal and stakeholder risks in all jurisdictions, as regulatory environments become more complex and politically charged.
Key Actions: The UK FCA has introduced the Consumer Duty, which shifts focus from compliance to customer impact. Similar measures are emerging in the US and Canada, while APAC regulators remain more focused on inclusion and digitization.

2. Economic Environment and Customer Impact

Economic Challenges: High inflation, monetary tightening, and the threat of recession are shaping regulatory priorities.
Customer-Centric Regulation: Regulators are increasingly concerned with the broader impact of financial products on customers, not just access.
SME Support: As government support for SMEs wanes, regulators are scrutinizing how banks treat these customers, with examples like the UK FCA’s "Dear Chair" letter.

3. Digital Assets

Regulatory Evolution: Oversight of digital assets, including stablecoins and crypto, is evolving, with a focus on transparency, consumer protection, and systemic risk.
EU and MAS Initiatives: The EU has moved toward regulatory clarity with the Markets in Crypto-Assets (MiCA) proposal, while MAS has imposed restrictions on crypto promotion.
CBDCs: Central bank digital currencies (CBDCs) are gaining interest globally, with the Eurozone and China leading in development. CBDCs may be used for wholesale transactions or retail access, depending on policy goals.
Challenges: CBDCs raise questions about monetary policy, privacy, and integration with the private sector. The FSB has proposed a framework to reduce regulatory fragmentation.

4. Digitization of Financial Services

Technological Impact: AI, cloud computing, and non-bank players are reshaping financial services, creating new risks and opportunities.
Regulatory Approach: Most regulators apply "same rules for same risks" to technology-driven activities rather than the technology itself.
Risk Management: Banks are embedding AI-related risks into existing frameworks and advocating for "risk management by design."
Tech Interconnectedness: Big tech firms are increasingly involved in financial services, prompting hybrid regulatory approaches, increased disclosure, and potential codes of conduct.

5. Environmental, Social, and Governance (ESG)

ESG Challenges: Regulations on ESG are growing in complexity and volume, with a focus on preventing greenwashing and managing climate risks.
EU Leadership: The EU has introduced the Sustainable Finance Disclosure Regulation (SFDR) Level II and is developing the Corporate Sustainability Reporting Directive (CSRD).
Global Standards: The International Sustainability Standards Board (ISSB) is leading the development of global ESG standards, while the European ESRS is expected to be more comprehensive.
Scenario Analysis: Regulators are updating climate risk assessments using the Network for Greening the Financial System (NGFS) scenarios, which include physical and transition risks.

6. Financial Crime

Increased Scrutiny: Financial crime remains a key regulatory focus, with regulators applying the lens of systemic risk to high-profile targets.
Enforcement Actions: The SEC and other bodies are using enforcement to address issues like greenwashing and misleading compensation disclosures in crypto.

7. Strategic Agility and Operational Resilience

Adaptability: Firms must be agile in responding to regulatory changes and maintain operational resilience in a complex and volatile environment.
Compliance Evolution: Compliance is shifting from a box-ticking exercise to a strategic and holistic approach, especially in areas like ESG and digital services.

8. Prudential Regulation

Risk Management: Prudential regulation continues to emphasize the need for robust risk management frameworks, particularly in light of emerging technologies and global market dynamics.
Interconnected Risks: The increasing interconnectedness of financial and tech sectors requires regulators to address both direct and indirect risks across the financial ecosystem.

Recommendations for Firms

Enhance Technology Understanding: Senior leaders should deepen their knowledge of digital technologies and their implications.
Integrate Digital Activities into Risk Frameworks: Firms should embed digital operations into existing risk and compliance systems, especially for operational resilience.
Address ESG and Climate Risks: Companies must align with global ESG standards and incorporate scenario analysis into their risk management practices.
Prepare for Regulatory Shifts: Anticipate changes in regulatory approaches and proactively adapt business models to align with evolving expectations.

Conclusion

The regulatory environment for financial services is becoming more complex and dynamic, driven by geopolitical shifts, economic volatility, digital transformation, and ESG demands. Firms must balance innovation with compliance, anticipate regulatory trends, and ensure they are prepared to adapt to the evolving landscape. Regulatory clarity and global cooperation are critical to managing these challenges effectively and fostering sustainable growth.

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