Wealth & Finance Issue 5 2018

Issue 5 - 2018

Providing Expert Financial Advice Synovation Financial Services Preserving a Heritage of Excellence

Researching Governance for a Better Investment Magni Global Asset Management LLC is the global leader in country-level research on corporate governance.

We profiled the leading firm and its team which gave us an insight into the company’s success. www.wealthandfinance-news.com

www.wealthandfinance-news.com

Editor’s Comment In the fifth issue for 2018, we cover a vast range of subjects from financial advisors, education and training specialists, and alternative asset management firms. This month’s issue is packed full of insightful articles for you to read.

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In recent news, GCM Grosvenor announced that its Labor Impact Infrastructure business has adopted a Responsible Contractor Policy that includes an agreement to proactively collaborate with the North America’s Building Trades Unions (“NABTU”).

The policy will ensure “responsible contractors,” including contractors who are signatories to collective bargaining agreements, are part of the bidding and selection process for its Labor Impact investments.

In this month’s edition, we discover more about Learn to Trade, which is a forex education and training specialist. The firm offers a range of courses that help people learn about and understand the forex market and the opportunities and risks within it. We recently spoke with their CEO, James Matthews who provided us with an insight into the firm and the exceptional services they provide.

Founded in 2008, Magni Global Asset Management LLC developed the Sustainable Wealth Creation principles, based on widely accepted economic concepts, by researching the accounting, legal, regulatory, adjudicative, and economic infrastructures of countries. Today, they are a global leader in country-level research on corporate governance. We profiled the leading firm and its team which gave us an insight into the company’s extensive accomplishments.

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Elsewhere in this issue, Constantine G. Varley is a financial advisor attached to Synovation Financial Services, and specialises in a vast range of services. Recently, we caught up with Constantine to discover more about both his work and successful company, Synovation Financial Services.

Here at Wealth & Finance Magazine, we hope that you thoroughly enjoy reading this month’s edition, and look forward to hearing from you.

Jessica Daykin, Editor j.daykin@aiglobalmedialtd.com

AI Global Media, Ltd. (AI) takes reasonable measures to ensure the quality of the information on this web site. However, AI will not assume any legal liability or responsibility for the accuracy, correctness or completeness of any information that is available through this web site. If errors are brought to our attention, we will try to correct them.

The information available through the website and our partner publications is for your general information and use and is not intended to address any particular finance or investment requirements.

In particular, the information does not constitute any form of advice or recommendation by us or any of our partner publications and is not intended to be relied upon by users in making or refraining from making any investment or financial decisions.

Appropriate independent advice should be obtained before making any such decision. Any arrangement made between you and any third party named in the site is at your sole risk and responsibility.

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Learn to Trade

4. News 6.

Preserving a Heritage of Excellence

10.

Providing Expert Financial Advice

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High Quality Strategic Specialist Advice

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Wildly Creative and Totally Geek

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Preserving a Heritage of Excellence

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Wildly Creative and Totally Geek

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Anti-Money Laundering- Blind Justice or Justice That Turns a Blind Eye

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Could your Business Tolerate a Good Ending?

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Debunking Five Crucial GDPR Misconceptions

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Explaining the Unexplained

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Mapping the Surge in Popularity of the Tier 1 Investor Visa

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News

GCM Grosvenor’s Labor Impact Infrastructure Business Adopts Responsible Contractor Policy Policy aims to promote competitive process and high standards for infrastructure investments.

GCM Grosvenor is a global alternative asset management firm with approximately $50 billion of assets under management in hedge fund strategies, private equity, infrastructure, real estate and multi-asset class solutions. It is one of the largest, most diversified independent alternative asset management firms worldwide.

“It is rare to find a firm such as GCM Grosvenor that brings the sophistication of a global investment platform and embraces the values of the labour movement,” said Sean McGarvey President of NABTU. “GCM Grosvenor’s Responsible Contractor Policy is as good as any we have seen for workers and communities, if not better.”

GCM Grosvenor today announced that its Labor Impact Infrastructure business has adopted a Responsible Contractor Policy that includes an agreement to proactively collaborate with the North America’s Building Trades Unions (“NABTU”). The policy will ensure “responsible contractors,” including contractors who are signatories to collective bargaining agreements, are part of the bidding and selection process for its Labor Impact investments. Through this policy, GCM Grosvenor will promote fair benefits, wages, working conditions and training opportunities for covered workers on projects for GCM Grosvenor’s dedicated Labor Impact Infrastructure business.

GCM Grosvenor’s Responsible Contractor Policy is among the strongest in the industry, reflecting its continued collaboration with leaders in the labour community. The policy covers project construction, renovation, operation and maintenance. Projects must meet criteria, including: •

A bidding process that is competitive and includes responsible contractors, including signatory contractors;

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Selected contractors must demonstrate a history of providing fair wages and benefits, compliance with federal, state and local laws including, but not limited to, wages, insurance benefits, occupational health and safety, and non-discrimination;

Labor Impact Infrastructure investing is investment in infrastructure that relies on a collaboration with union labour to unlock infrastructure opportunities • and generate high quality risk-adjusted returns, while creating an enduring pos• itive impact on organised labour.

“Sean McGarvey and North America’s Building Trades Unions have shown tremendous leadership pushing a pro-investment and pro-worker agenda.

What they have worked toward is the smartest way to approach infrastructure and their efforts should transform the infrastructure investment industry,” said Michael J. Sacks, Chief Executive Officer of GCM Grosvenor. “This Responsible Contractor Policy reflects our values and is an important starting point for any firm that is serious about infrastructure in North America.”

•

Promotion of Project Labor Agreements; Recognition of employee training and safety and protection of workers’ rights; and Certain advanced notification to national and local building trade organisations of project and bidding opportunities and reasonable time to seek union labour for various functions.

Additionally, the Labor Impact Responsible Contractor Policy contains enforcement mechanisms designed to ensure strict adherence to the policy provisions.

Expanding Access to Alternative Investment Strategies J.P. Morgan Asset Management announced on the 17th May 2018 an agreement with iCapital Network (“iCapital”) to provide a white label offering exclusively for Registered Investment Advisors and their clients to access a select group of J.P. Morgan Global Alternative strategies. As a part of this agreement, iCapital, which has created a sophisticated technology platform that simplifies access to alternative investments for eligible investors, will partner with J.P. Morgan Asset Management to provide high net worth investors with platform access to certain J.P. Morgan Global Alternative strategies.

“As we get later in the economic cycle, identifying alternative sources of return is an essential consideration for investors looking to build stronger portfolios. Institutional clients have long embraced alternatives as a strategic part of their asset allocation, and many high-net-worth investors continue to be under-allocated to alternatives relative to their institutional counterparts,” said Anton Pil, Managing Partner of J.P. Morgan Global Alternatives. “Given the current rising interest rate environment, investors are looking for alternative sources of income that provide diversification to broader fixed income markets, and as a result, we are starting with several of our income-focused Alternative Investment strategies.” “iCapital’s industry-leading financial technology platform solves a critical need and will allow us to expand access to our alternative investment capabilities among a wider audience. We anticipate that we will launch additional strategies over time,” said Christopher Hayward, Managing Partner of J.P. Morgan Global Alternatives.

“My colleagues and I are delighted that J.P. Morgan Asset Management has partnered with iCapital to power its alternative strategies platform,” said Lawrence Calcano, Chief Executive Officer of iCapital Network. “We are committed to democratising alternative investments by providing unparalleled technology to advisors and their high-net-worth clients that improves the experience of allocating to new exposures and strategies.”

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Researching Governance for a Better Investment Magni Global Asset Management LLC is the global leader in country-level research on corporate governance.

We profiled the leading firm and its team which gave us an insight into the company’s success.

Founded in 2008, Magni developed the Sustainable Wealth Creation principles, based on widely accepted economic concepts, by researching the accounting, legal, regulatory, adjudicative, and economic infrastructures of countries.

Its extensive database goes back 17 years and contains analysis on countries across 280 qualitative factors. The Minnesota-based research and asset management firm believes Countries Matter™ when investing internationally; and Magni scores and ranks investable countries on their ability to provide an environment conducive to effective corporate governance.

Around the world there are almost daily news stories about corruption by people in corporations and by government officials. The post-Cold-War euphoria for the global spread of capitalistic democracies has given way to a declining trust in institutions. This shift is one of the reasons for the increased focus on bringing ethics to finance.

Initiatives to convert the focus into action use many names, including Socially Responsible Investing, ESG investing, Impact Investing, and Responsible Investing. Fortunately, these initiatives are increasingly collaborating through organisations such as PRI. The growing assets defined as part of Responsible Investing are proof of its impact. After all, the US SIF Foundation reports the total US-domiciled assets under management using SRI strategies grew to $8.72 trillion at the start of 2016, an increase of 33% since 2014 and a 14-fold increase since 1995. Despite being an impressive number, the US has an atypically small share of Responsible Investing assets; especially when compared to European countries where the focus is more pronounced.

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Historically, investments where ethics and values are applied have had challenges in yielding performance consistent with traditional benchmarks. More recently, the concern has subsided some with such investments outperforming traditional investments, highlighting their increased importance in the market.

Research and academic studies show governance is an important consideration to achieving or exceeding benchmarks when constructing portfolios, especially ESG portfolios. Countries with good governance tend to have superior environmental and social performance.

Furthermore, recent research shows companies with good “G” also tend to have good “E” and “S” performance. Simply put, good governance can drive good environmental, social, and investment performance. As Martin Gilbert, Chief Executive of Aberdeen Asset Management, stated, “The governance of countries affects the ability of companies to generate value within them, and it is in everyone’s interests to enhance the framework for business.”

Honesty and transparency are the foundations of good governance. After all, fraud, corruption and other undesirable actions can more easily occur in opaque environments. The greater the demonstrated honesty and transparency, the lower the risk of adverse news harming equity valuations and the greater the opportunity for a positive impact.

An example of this can be found in the corruption scandals that have historically been reported in countries around the world. For years many investors focused on the BRIC countries within the emerging markets (i.e., Brazil, Russia, India, and China). Money poured in driving up valuations because of the perceived opportunities. Yet

corruption scandals, such as Odebrecht in Brazil, are evidence of systemic corruption and have tainted the BRICs. Many elected officials in Brazil are in jail or facing criminal charges.

Today the corruption in Russia is so extensive, particularly among the oligarchs, that a website is dedicated to tracking such activities, including money laundering and illegal activities. There are also widespread requirements for bribes in India to get favourable treatment by lower-level government officials and courts. In China, western auditors have had to resign from company assignments as the auditor cannot attest to the financials. Corruption makes valuation more difficult as financial projections are suspect and future profits may benefit the perpetrators of corruption more than shareholders.

Corruption is not limited to these four countries.

It exists in every country; even countries of the developed markets. At the end of the last century, some companies in the United States collapsed due to accounting fraud.

Countries have laws and regulations to prevent corruption. For someone to understand the actual level of corruption in a country, more than reviewing the laws and regulations on the books is required. Magni differs from other research organisation by focusing on behaviour rather than mere assertions.

In Magni’s view, governance is measured by how a country or company regulates both itself and the people who are part of its environment, and importantly how it interacts with its constituents.

Countries must demonstrate the ability to create an economic, legal, and regulatory environment where output can grow, investment opportunities are attractive, and investor rights are protected.

Researching Governance for a Better Investment

Company: Magni Global Asset Management LLC Contact: Kurt Lieberman Address: 11375 Entrevaux Drive, Minneapolis, Minnesota, 53347, USA Phone: 612-548-1470 Website: www.magniglobal.com and www.magniglobal.com/governance-indexes/

“The Magni Difference: Looking Below the Surface for Essential Information.�

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www.wealthandfinance-news.com Researching Governance for a Better Investment

Companies must demonstrate strong, deep relationships and the transparency to reduce the risk of corruption and malfeasance. This is a much more nuanced approach than a “check the box” exercise done by some research organisations. It is important to determine the actual behaviour of the country or company versus its stated intent.

Most analyses focus on the stated intent that is akin to the visible part of an iceberg. However, the important information, the actual behaviour, is like the submerged portion of an iceberg. The key to success is researching and incorporating this hard to find information. Therefore, an iceberg is an excellent metaphor for traditional analyses regarding countries and companies.

Most active and passive approaches to international portfolio construction ignore the fact that every country has unique legal, regulatory, and economic infrastructures. The resulting differences in individual country economies have implications for equity valuations. If company-level measurements impact financial projections and those projections are very important to investment decisions, then country-level measurements should equally impact investment decisions.

When considering international equity investments, investors should seek to determine the following: •

an important survey on the role of country governance in investing. In the survey, 89% of respondents agreed that effective governance is a critical driver of investment performance. However, the increased awareness of the importance of countries is not usually part of portfolio construction as traditional investment analysis does not include country considerations.

Do financial statements accurately reflect a company’s position?

Are shareholders protected and is there appropriate and effective regulation?

Can company leadership make decisions confidently and without interference from a corrupt government?

To support investors in making informed decisions, Magni has replicable research and investment processes for turning key insights about governance into investment information and indexes, simply by scoring all investible countries in the world based on their demonstrated record of good governance.

The significance of these questions can be validated with examples from around the world.

Much traditional investment analysis is grounded in spreadsheets forecasting future profits of a company. The projections imbedded in these spreadsheets are usually mere extrapolations from recent financial statements. Thus, since the financial statements of companies in China are not always reliable or accurate, the resulting projections of these companies’ future values can be highly inaccurate. Using unreliable and/ or inaccurate financial statements to create forecasts of future financial performance, is counterproductive and is likely to lead to suboptimal investment decisions.

The firm recognises that when it comes to investment decisions, Countries Matter™. Magni’s research database is based on the Sustainable Wealth Creation principles and contains data on 280 Qualitative Sovereign Factors grouped into 12 Economic Standards. Research on the Qualitative Sovereign Factors is accumulated to determine a score for each Economic Standard and then combined into an overall Magni Country Score. The higher the country score, the greater the adherence to the Sustainable Wealth Creation principles, the greater the weighting in the index.

• •

Country specific risk considerations are also key to establishing the value that can be found in a specific investment. Companies create value by deploying capital on opportunities. The ability of a company to convert the opportunity into value is impacted by a spectrum of risks. When a country provides a healthy environment, companies face less country risk. Low country risk means more projects to create value are attractive and projects are more likely to produce the desired result.

Simply put, more value can be created when risk is minimised by a healthy environment. Thus, country-specific considerations have a material impact on the value of a company.

Increasingly investment professionals are beginning to realise the importance of countries. In 2015, Gabriel Research & Management conducted

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Fundamentally, good corporate governance is based on the same foundation as good country governance: honesty and transparency as assessed through corporate behaviour.

Country governance is granular as it assesses the infrastructure of a country, while company governance is detailed in that it assesses the stakeholder relationships. The two analyses are closely related. Magni’s Corporate Governance Assessment takes the research methods used on good country-level governance and applies them to a best practices model for corporate governance, thus creating the Sustainable Value Creation principles. These principles analyse 316 qualitative factors for each company. Magni not only assesses each company’s relationship with its shareholders and employees, but also with its customers, suppliers, competitors and the community in which it operates. This approach provides a complete and holistic analysis of

governance that incorporates the social aspects of ESG investing.

The secular model used by Magni has also been integrated with religious guidance to create the Catholic Values and Islamic Stewardship models for corporate governance. Most traditional models for faith-based investing just use negative screening. In these traditional models, companies are excluded from a portfolio based on a list of prohibited products or activities. Such negative screening is important, yet religions have guidance on behaviour regarding that which is desired and considered good.

The religious models from Magni differ from most traditional religious portfolios by including the guidance regarding good behaviour. The Catholic Values model integrates Catholic guidance for business from chapters 7 and 8 of Catholic Social Teachings. The Islamic Stewardship model integrates Islamic guidance for business from the Maqasid. The Maqasid are the overarching objectives of Shariah. While the three corporate governance models have many areas of overlap, each is different as the Catholic Values and the Islamic Stewardship have topics uniquely relevant to the specific religion.

Magni has created six governance indexes, three international indexes on countries and three corporate indexes using the companies in the US S&P 500. Across each of the governance assessments, Magni generates scores for countries and companies. The scores are used to determine allocations in each index, which are available on Bloomberg, Thomson Reuters, and Magni’s own website.

Academic studies are confirming what Magni already knows: governance is important investment information and a focus on governance has been shown to be a driver of performance.

With 17 years of data, Magni can show the importance. Governance is much more than a “check the box” activity. Governance is about honesty and transparency. Honesty and transparency need to be assessed by observing behaviour. As with an iceberg, this essential information is not easily seen but should be used to make good investment decisions.

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Providing Expert Financial Advice Constantine G. Varley is a financial advisor attached to Synovation Financial Services, and specialises in a vast range of services. Recently, we caught up with Constantine to discover more about both his work and successful company, Synovation Financial Services.

Constantine G. Varley is a financial advisor attached to Synovation Financial Services, and specialises in a vast range of services such as life insurance, disability cover, risk planning and various investments to name a few. Constantine begins by providing us with an overview of the expert services he can provide to clients.

“The combination of my personal background, experience and qualifications allows me to provide expert financial advice. Together with my skilled team of support personnel, I can help clients with the implementation of a holistic personal plan to achieve all their financial goals. Additionally, I am able to supply valuable knowledge and guidance along their journey to financial wellbeing.”

In 1990, Constantine passed the CEA (Certificate of Estate Agents) examinations after which he entered the financial industry in 1991. Initially, he established himself within the industry with Old Mutual, where he obtained various awards as a top achiever in different products.

In 1995, he qualified at the University of the free State as a Certified Financial Planner. Fast forward to 1999, where he joined Pentagon, and in the year 2000 he began the Fourth Dimension Financial Services alongside 21 other brokers.

In 2001, he started Synovation Financial Services where he is still a key individual within the firm.

A few years down the line in 2017, Constantine joined Attooh! He is involved with the local community radio station, having been involved there since its inception in 1995, where he has been a director since 1996, later becoming the Chairman of board of directors from 1998 to Jan 2018 when he step down after nearly 22 years of service.

Constantine serves on numerous governing bodies as trustee. Also, he is a director of various

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companies and trustee of many trusts. Additionally, he is involved with various other businesses, including property developments. Taking time to explain his approach to work, Constantine highlights how his honest outlook has helped him throughout the years.

“As a whole, I believe in not selling something to my clients which I, myself, would not buy or invest in, nor which I would not recommend to a close relative. Instead, I believe in taking the middle path, so that I am confident when I meet a new client. Additionally, I believe that if I can help you to achieve prosperity, I too will benefit in the long run.”

Bringing the interview to a close, Constantine understands that in this volatile economic climate, it is important to remain focused. With the necessary expertise and goal-orientated plan, he is able to assist clients within each aspect of your financial portfolio. With his goal set to guide clients to financial success, providing them with protection for their dependents, businesses and employees against unforeseen events, Constantine is able to add value in their journey to financial freedom.

In co-operation with the Attooh! Group of Companies and with an expert team of support personnel, Constantine provides an authoritative hand in the planning of the financial future of his clients’ needs. Passionate in his guidance of helping his clients to reach their financial potential, as well as ensuring that they achieve financial success, Constantine reveals to us how he stays motivated to provide clients with exceptional levels of service.

“Overall, I strive to continually improve myself, my skills and knowledge in all aspects relevant to the services and products on which I advise, in order to provide the very best, seamless financial solutions.”

Providing Expert Financial Advice

Contact: Constantine G Varley Company: Synovation Financial Services 3 Tre Mondi Park Niblick Way, Somerset West, Western Cape, South Africa, 7130 South Africa Telephone: 083 4451165 Web Address: www.constantinevarley.co.za

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High Quality Strategic Specialist Advice Geordie Bulmer recently established a new company within the AISA Group called AISA Retirement Planning. This part of the business will be based in the South West and will specialise in helping clients plan and structure their retirement goals. It will also specialise in Estate Preservation through effective tax planning, which is an area that was recently recognised by the Wealth and Finance Tax Planning Award.

The award follows Geordies Inheritance Tax Planner of the Year 2018 award and last year AISA received a number of awards including Retirement Planner of the year (South West region) Excellence in Investment Planning (UK) and Best Best-Practice, (Europe, UK and Overall Winner). The company is proud of these achievements as it helps confirm AISA’s ability to offer competent advice across a number of areas.

Retirement and Inheritance Tax planning has been the main focus for Geordie for over 10 years now. Not only has he provided competent investment advice, which has helped his clients grow their wealth considerably, he aims to make sure the correct ‘tax wrappers’ are utilised so that a healthy retirement income can be achieved with little or no tax liability. Where the clients are of a sufficient age or circumstances then he will advise on suitable Inheritance Tax solutions which allows them to pass on their wealth but does not restrict access to their funds during their lifetime.

He strongly believes that many areas of Financial Advice are not possible through ‘robo advice’, where clients make the decisions themselves, often using a flow chart structure where certain answers would lead a particular product. Geordie believes that new technology has helped financial advice in a number of ways, however speaking to an expert is extremely important when considering big financial decisions; “With regards to planning for your retirement, it is wise to involve an independent adviser at least 15 years before your planned retirement age. This should ensure the correct strategy can be put in place and monitored on a regular basis, so that you achieve your objectives in retirement. This may involve a Cash Flow forecast, use of different investment products that make use of different tax allowances and a suitable diversified investment portfolio, appropriate to you and your ability to tolerate risk.”

Geordie believes obtaining advice is even more important with Inheritance Tax solutions; “There are a large number of issues to consider when

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putting together a suitable Inheritance Tax strategy for clients, as everyone has different financial situations and objectives. Some people may be very keen to reduce the tax bill for their family and would therefore be happy to give assets away, where other clients may want to ensure they have access to their money should they need it in the future but they still want to mitigate their tax liability where possible. There may be a conflict in their objectives which could cause future problems, so taking appropriate independent advice from an Inheritance Tax specialist is very important.”

With the Finance industry changing all the time, Geordie aims to make sure he keeps on top of regulation changes and regularly attends Pension and Estate Planning seminars. This ensures that the advice he offers clients is up to date with current regulation but can be changed in the future if circumstances or legislation changes.

“Our strategy at AISA Retirement Planning is to offer clients an initial meeting where we find out as much as possible about their current circumstances and future objectives, including details around their family members to ensure everyone is included. Then a Financial Strategy can be tailored to their specific circumstances and ideally monitored on an ongoing basis. Clients can choose to just receive initial advice and not sign up to an ongoing service, but we would recommend keeping in touch so that the advice can be monitored and updated where appropriate.”

Geordie has based the AISA Retirement Planning in Bristol as he believes it to be a great city to run a Finance company from. The reason being is that there are a vast number of established Investment and Life offices and therefore, many potential employees with good financial knowledge and qualifications in the local area. In addition to this, he is also planning to gradually grow the business with a main focus on offering the right advice to clients and building a strong reputation.

Company: AISA Retirement Planning Name: Geordie Bulmer Web Address: www.aisaretirementplanning.co.uk Address: Oakenhill Lodge, Bonville Road, Bristol, BS4 5NX Telephone: 0117 971 3117 / 07767 354497

High Quality Strategic Specialist Advice

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Wildly Creative and Totally Geek Bulldog is a modern marketing agency exclusively focused on complex B2B. Which means rich experience in leading strategic insights, planning and execution of highly technical and creative marketing programs.

Recently, we spoke to Robin Campana to find out more about the firm, and their wildly creative ways.

Bulldog is a modern marketing agency exclusively focused on complex B2B. Their seven practice areas consist of integrated planning, content (analysis, planning, creation), marketing technology services, demand creation, opportunity acceleration, account-based marketing and influencer/advocate marketing.

The firm works with enterprise brands in the tech, healthcare and financial industries. Some of our clients include: TD Ameritrade, Frontier Communications, Comcast Business, IBM, Box, DigiCert, Symantec, Silicon Labs, NCR, Humana, Oracle, Sage, WEX, Zebra and more. Going into more detail about Bulldog’s overall mission, Robin explains the steps the team takes to achieve their end goal.

“Bulldog’s purpose is that ‘we unleash the most curious and courageous B2B marketers on the planet’. At Bulldog, we have four core values: Curious, Courageous, Collaborative, Committed.

We look for these values in our people as we hire, retain and reward employees as they exhibit these values. Additionally, we look for clients that exhibit the same values with an emphasis on Curious and Courageous.”

Bulldog is a leading B2B digital marketing agency in a growing and complex market. The B2B technology market is becoming increasingly competitive as new entrants and innovations disrupt the current status quo. The market is growing quickly and is expected to exceed $578 billion in size by the end of 2018. The purchasing decisions for Bulldog’s clients are more complex than the B2C market, as Robin informs us.

“At Bulldog, our expertise helps our clients navigate these decisions. Capabilities across strategy, creative, technology and analytics enable Bulldog to deliver impactful growth solutions. We bring measurable ROI from solving complex issues

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for our clients around revenue growth, customer retention, M&A integration and lead generation just to name a few.”

A few of the brands we proudly support...

The speed at which technology is changing, is requiring businesses to think more agile. B2B enterprise marketing teams are struggling to keep up with changing buyers, new technologies that change the way they work and the sheer complexities of their own organizations. Robin goes into detail about how the firm ensures that they stay ahead of these emerging developments within the industry.

“Over the years, we’ve seen that clients are turning to technology to solve problems. However, they’ve discounted the organizational change necessary to realize value from the technology.

These complexities are creating real challenges in how our clients design their teams with the right people, and the skills to produce results that the C-suite cares about. Here at Bulldog, we bring deep expertise in guiding our clients through this complexity.”

It is no secret that behind every successful company, there is a team of talented individuals, who in addition to helping the firm keep ahead of emerging developments, also use their creative and technical abilities to provide clients with exceptional levels of service, as Robin explains.

“Our culture is ‘Wildly Creative and Totally Geek.’

Whether we’re researching and designing a marketing program, a technology stack, or a content strategy, we bring both technical and creative leaders to the table. This allows us to bring humanity and beauty to highly technical service offerings, as well as a technical discipline to highly creative offerings. In a world where marketing agencies tend to lean very heavily towards either technical or creative, this balance is a real differentiator for us. To retain our wildly

creative and totally geek talent, we use the Irresistible Workplace model to cultivate a great culture.”

Looking ahead, both Robin and the rest of the senior executive team have a vision for Bulldog that the company will continue its growth trajectory for years to come. In her concluding comments, Robin envisions how the company will continue that growth trajectory.

“Our future plans at Bulldog revolve around growth. Growth as individuals, as teams, for our clients, as well as growth in revenue and profitability. If we grow as individuals and teams, and also help our clients to develop and grow, then the growth in revenue and profitability will take care of itself. Bulldog is on track to grow revenue by 25% in 2018, and is maintaining 50%+ of revenue generated from long-term contracts YOY.”

Wildly Creative and Totally Geek

Contact: Robin Campana Company: Bulldog Solutions, Inc 7500, N. Capital of Texas HWY, Suite C250, Austin, Texas, 78731 Telephone: 001 877 402 9199 Web Address: www.bulldogsolutions.com LinkedIn: www.linkedin.com/in/ robincampana

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Preserving a Heritage of Excellence Proserv is a global leader with a worldwide presence, offering a fresh alternative in the delivery of engineering and technical services to the energy, process and utility markets. We spoke to Andy Anderson, Regional President MEA at Proserv, to find out more about the company and its innovative services.

Andy, could you begin by providing our readers with a brief overview of Proserv Middle East and the services you offer?

“Proserv is a global leader and a fresh alternative in the delivery of engineering and technical services to the energy, process and utility markets, supporting clients throughout the lifecycle of their assets. We operate in six regions throughout 22 facilities and 12 countries, offering 24/7 local support services. Core to the Proserv offering is our ability to manufacture, deliver and support solutions locally through our highly experienced pool of technicians and engineers.

“We have been based in the UAE for over 25 years, largely servicing customers across the energy sector, including offshore and onshore services, equipment design and manufacturing.

Proserv has supplied the vast majority of installed wellhead controls in the region through its legacy brands – Brisco, CAC and eProduction Solutions.

“We deliver a broad range of hydraulic safety shut down systems for wellheads, chemical injection systems, downhole and surface sampling systems, from bases across the region; all of which are backed up by a strong technical team who are able to install, commission and maintain equipment in the field.”

Talk us through your approach to client service.

How do you maintain the high standards synonymous with the Proserv brand?

“Meeting and exceeding our clients’ expectations is vital to ensuring our ongoing success. We strive to develop and maintain this through establishing business relationships built upon experience, competency and trust. We focus on regular faceto-face engagement with our clients, taking the time to understand their requirements.

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“We then revert with a solution that is in line with our company ethos - Ingenious Simplicity. This concept is based upon challenging convention in an industry that continues to ‘over engineer’.

Ingenious Simplicity is about being flexible and responsive to clients’ needs, while reducing unnecessary levels of complexity in order to get the job done in a cost effective manner.”

Following on from this, what is it that makes Proserv Middle East unique? How do you distinguish yourselves from your competitors, and present yourselves as the best option for your clients?

“Proserv has an extensive brand heritage spanning over 40 years. Through our acquisitions, we have shown the importance of embracing this heritage alongside a commitment to constantly evolve and develop innovation.

“A key topic in our industry right now is ageing wells, and as a result E&Ps are searching for adequate partners to support their OEM requirements, without full system replacement.

Many parts for the old wells are now obsolete or superseded and so Proserv has recognised this and positioned itself as a partner of choice who can re-engineer the part required to maintain production.

“Also, we actively listen and collaborate with our clients to find cost effective solutions for their maintenance and production issues. A great example of this was the development of our cost-effective Smart Box solution. Also, we are currently working on the development of an Asset Enhancement Global Intelligence Solution (AEGIS), which will be released, to our customers this June.

Company: Proserv Middle East Address: Jebel Ali Facility, Jebel Ali Free Zone, Dubai, 16922, UAE Phone: 00971 4 808 3500 Website: www.proserv.com

Preserving a Heritage of Excellence

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In order to provide quality services, exceptional staff are crucial, so please tell us more about the culture within Proserv Middle East and the things you do to maintain and develop it. What do you look for when attracting new staff and how do these traits help them integrate into your company?

“Our growth is driven by a team of dedicated and talented people who provide the company with expertise in engineering and business, creating pioneering solutions that allow us to remain competitive. As a service EPC, our people are our biggest asset and we nurture an environment that encourages creativity and employee-driven innovations.

“In the UAE, we employ more than 20 different nationalities and unite through a clear set of values. The five values – encompassing teamwork, service, communication, entrepreneurship and right thing, right way, guide each of our decisions and behaviours. When we recruit new people to join our team, we look beyond a person’s technical ability and experience and place emphasis on ensuring a person’s values are aligned to Proserv’s. Internally, we provide training for our staff, encouraging continuous development and learning through our internal ‘Proserv Academy’.

One example is our ‘technician training school’ which we have developed and implemented for the needs of our Saudi business. The school will enable many young Saudis to gain the necessary skills to learn and develop as part of the Proserv family.”

As your regional headquarters are in the UAE, can you please tell us a bit more about the opportunities and challenges you experience being based there?

“The UAE has the world’s seventh largest proven reserves of both oil and natural gas, estimated at 97.8 million barrels and 215 trillion cubic feet. There is no doubt that oil will continue to provide income for both economic growth and the expansion of social services for decades to come. In the coming years, natural gas will play an increasingly important role in the UAE’s development – particularly as a fuel source for power generation, petrochemicals and the manufacturing industry.

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“The industry itself is going through a difficult transition; CAPEX is not always a viable option for our end user clients and OPEX is typically only being spent to perform safety or production critical work. However, with ADNOC being restructured and the oil price creeping up towards $70 per barrel, new investments are planned for the short/ medium term. These challenging times have called for a fresh approach in maintaining operational efficiency, whilst decreasing OPEX through scheduled and maintained inspections, but also longer term planning. Our approach has been to offer services across the complete life of field through locally supplied products and services.

We have existing long-term service contracts with our clients, where we have proven we can repair or upgrade existing assets, rather than replacing them, thus enabling them to maintain production and reduce downtime at a fraction of the cost.

“The UAE serves as a Centre of Excellence for Proserv’s growing business and organisational presence in the Middle East and Africa market.

Our regional headquarters and equipmentmanufacturing facility is located in Dubai, while the service centre is located in Abu Dhabi.”

In your opinion, what are the key advantages to being based in the UAE? Are there any core areas of growth that you believe make it the ideal hub for your business?

“For some time, the UAE has been viewed as an energy hub/gateway for the Middle East region.

While many companies located in the UAE solely distribute products made in the USA/EU across the Middle East market, Proserv manufactures and provides services from its local facilities in both Dubai and Abu Dhabi.

“Proserv recognises that the best support for our clients is achieved by local, in country support.

The energy industry is a 24-hour operation, and, as such, has a need for timely service capability.

We are able to immediately mobilise service engineers/technicians with local visas/work permits to address unplanned events that can cause our clients expensive downtime via lost or reduced production. Also, we provide client specific intelligence solutions to map and track inventory parts, enabling us to provide or quickly call off replacement parts. Our focus remains on worldclass respond and resolve solutions.”

Reflecting on the past 12 months, what have been the most prevalent trends in your industry and how has your business adapted around these?

“Last year was a year of innovation for us. Our track record, coupled with our ability to create new value for our clients, allows us to continue to expand our business. The opening of our facility in Saudi Arabia - an Aramco Approved Manufacturing and Service Facility – was a key moment for us back in 2016 with the region very much continuing to be a key growth market for us.”

Looking ahead, what does the future hold for Proserv in the Middle East? Do you have any future plans or projects you would like to share with us?

“Moving forward, Proserv will continue to secure its footprint within the GCC through the establishment of a Manufacturing & Service facility in KSA, as well as investing in expanding our service centre in Abu Dhabi. This will further strengthen our capabilities and capacity to service the increasing demand for our product and services within the region.”

Preserving a Heritage of Excellence

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1804WF03

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Wildly Creative and Totally Geek Learn to Trade is a forex education and training specialist. The firm offers a range of courses that help people learn about and understand the forex market and the opportunities and risks within it. We recently spoke with their CEO, James Matthews who provided us with an insight into the firm and the exceptional services they provide.

Learn to Trade is a forex education and training specialist. The firm offers clients a range of courses that help people learn about and understand the forex market, as well as the opportunities and risks within it, in courses run across the country taught by trained and experienced traders. Since their inception in 2003, the firm have trained more than 250,000 people in forex and trading so far. As for Learn to Trade’s mission, James informs us of how the firm provides high quality education in forex and trading, as well as the full range of courses which they have designed.

“Here at Learn to Trade, our mission is to provide people with the high quality education in forex and trading, that provides them with the knowledge that will help them to trade. We have designed a full range of courses that can help people gain insight into the market, and the opportunities and risks within it. Understanding all of this is crucial before anyone starts trading their own money.

“In addition to this, we want to be the best forex training and organisation in the world, and as such, we approach all interactions with our clients with this in mind. Our trainers and mentors come with a huge amount of experience, and they all aim to provide personalised expertise and coaching to every one of our clients. With trading, markets change on a daily basis, and having these traders on hand to understand what is happening to clients and provide guidance on how to read the market is very important for us.”

It is no secret that behind every successful company is a team of dedicated individuals who work tirelessly to ensure that they achieve their clients’ requirements. For Learn to Trade, one of the biggest parts of their culture is their focus on corporate social responsibility, as James explains.

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“15% of pre-tax profits from Learn to Trade go to the charitable foundation which was set up by our founder, Greg Secker, which aims to empower young people. Many of our employees have supported The Greg Secker Foundation’s various projects and initiatives, including the building of 100 houses in the Philippines for people affected by the Typhoon Haiyan in 2013, as part of the 52 paid volunteer hours they are entitled to each year.

As for where the company is located, James reveals why she believes the region Learn to Trade operates within is the ideal hub for the firm.

“Currently we operate trading courses within a number of countries, including South Africa, Australia, Philippines and the UK. This is in reality just the start for us, and we have plans to make these courses available to people across the world. We believe that anyone that wants to trade should be able to, and it should not be just for banks and hedge funds.

“Trading is now more accessible to more people than it has been before, which is really exciting and there is a growing general awareness of trading, and more courses and training are now available

in forex. There is also some fantastic trading technology out there for people to use, such as our charting software of choice, SmartCharts, which makes it easier than ever before to access opportunities in the market, thanks to the intelligent algorithms and systems that run within it.”

Looking ahead to what the future holds for the business, James notes the growth the company has seen over the years, and envisions that it will continue in the years to come, as well as noting on the developments within the wider industry.

“It’s an exciting time for the industry now. With advancements in technology over coming months and years, we will see even better tools and software to help anyone trade. Later this year, we will launch version 2 of SmartCharts trading software, which features some of the latest technology available, which is very exciting for us.

“Over the past six years, we have seen a 30% growth in people looking to learn to trade with us, and we expect this to continue to grow. This, together with our expansion globally, means we will be training thousands more people in how to trade every month.”

Wildly Creative and Totally Geek

Company: Learn to Trade Web Address: www.learntotrade.co.uk Twitter: @UKlearntotrade

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Anti-Money Laundering-

Blind Justice or Justice That Turns a Blind Eye International efforts to combat money laundering – which latterly have been closely connected with frustrating tax evasion and aggressive tax avoidance – and to staunch the supply of money to terrorist organisations have been coordinated by the Financial Action Taskforce, and have resulted in various series of FATF Recommendations and Special Recommendations.

and of redress, enabling them to continue as if the authorities had not intervened if it should turn out that the actions of the authorities were unwarranted.

This body of knowledge as to how to run a regime for AML/CFT has firstly been converted into law, for example via the EU Anti-Money Laundering Directives and its subsequent transposition into EU Member State law, an example of the latter being the UK’s 2017 Money Laundering Regulations.

In February 2018 Rabobank, a California unit of the Dutch cooperative bank, was reported to have agreed to pay over US$368 million for processing funds likely tied to drug trafficking and other illicit activity and it pleaded guilty in court to conspiring to obstruct regulatory oversight. It continued in business, however.

Secondly it has been used to set up national Financial Crime organisations to receive and investigate Suspicious Activity Reports (“SARs”), to monitor the compliance of those firms with responsibilities under AML/CFT – known as “obliged entities” – when measured against applicable law and regulation, and to impose sanctions on those that have failed to run a compliant regime.

Thirdly it has been used to create implementation guidance for “obliged entities” through international organisations like the Wolfsberg Group and national ones like the UK’s Joint Money Laundering Steering Group.

In the process a grey area has been created, however, that should not exist in a proper legal system: the enforcer of a law must be bound by it as much as the subject, and the same penalty must be imposed upon two different organisations committing the same offence.

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This is not the situation as it has emerged for “obliged entities” where breaches of the AML/CFT regime have been suspected.

In May 2015 BNPP was sentenced to five years’ probation by a U.S. judge at the time the bank agreed to pay US$8.9 billion to settle claims that it violated sanctions against Sudan, Cuba and Iran. It continued in business and in June 2017 it was reported as having been fined EUR10 million by the French AML/CFT regulator ACPR for inadequate anti-money laundering controls.

In 2012 HSBC paid US$1.9bn to the US authorities to settle allegations that it allowed terrorists to move money around the financial system, and it signed a Deferred Prosecution Agreement, which involved agreeing to the Department of Justice delegating an official to monitor HSBC’s progress at a reported cost of US$20 million annum.

Bizarrely HSBC later hired Jennifer Shasky Calvery as Head of Compliance to run their side of the monitoring process, the very official at the Department of Justice who had brought the suit against HSBC, and against the named position in the bank that she then came to occupy. In late 2017 the UK’s Financial Conduct Authority

commissioned a so-called “166 report” into the HSBC after the Department of Justice official raised concerns about the degree of progress.

These are examples of the penalties imposed upon major banks in the Western world, two of them being Global Systemically Important Banks according to the Financial Stability Board, where the banks have continued in business.

By contrast the authorities have been very quick to act in cases where banks are small and nonsystemic, and to stop them doing business.

On 21st March 2018 Malta’s regulators imposed a freeze on the business of Pilatus Bank after its chairman was arrested on charges of breaking U.S. sanctions.

ABLV in Latvia was closed down by the Latvian authorities immediately after it was served a notice 311 by FinCen – the financial crime arm of the US Treasury Department – on 13th February 2018 naming it as an institution of prime money laundering concern, and applying the fifth special measure to it: this forbids US banks from running a correspondent account for ABLV and from handling its payments on a pass-through basis.

Versobank in Estonia was closed down on 26th March by the Estonian authorities due to AML/CFT failings allegedly linked to the Russian elite and intelligence services.

The Estonian branch of Danske Bank – the major Danish and Nordic institution – was investigated by the Estonian Financial Supervision Authority around the same events as resulted in the closure of Versobank, but Danske’s Estonian branch remains open.

Anti-Money Laundering- Blind Justice or Justice That Turns a Blind Eye

This has been the pattern when dealing with smaller banks, and the test case for this approach remains that of FBME, the small and foreign-owned bank branch in Cyprus which was “resolved” in 2014 by the Central Bank of Cyprus (“CBC”). FBME had had a 311 Notice issued against it by FinCen imposing the same fifth special measure. CBC used the 311 Notice as its trigger to stop FBME doing business and take it over. In the four years since this occurred, however, CBC has failed to corroborate the validity of any of the cases of alleged money laundering that gave rise to Fin Cen’s 311 Notice.

There were no court cases involved in these examples. Authorities took swift actions and closed banks, creating a fait accompli against which there could be no adequate redress for the owners of these banks, even had they had an adequate right to receive redress. The banks were taken over, their ability to do business nullified and their reputation destroyed.

The rights of the subject to proper representation during the legal process, to transparency of process, and to a right of appeal have been duly bypassed.

Then we have the report on 13th April 2018 that the US authorities considered taking action against China Construction Bank and Agricultural Bank of China for alleged violations of international sanctions against North Korea. In other words

there was evidence to hand that these banks were routing payments to and from North Korea, although not necessarily in US$.

Given that the US authorities acted so quickly against FBME, ABLV and others, a 311 FinCen Notice imposing the fifth special measure would then have been expected. The US authorities must have had a body of evidence against these Chinese banks, but they apparently have significant latitude in deciding how to apply that evidence and, indeed, whether to use it at all.

It seems that the idea of taking any action was quickly shelved, primarily because of fears that punishing banks of that size might send shock waves through the global financial system. Indeed, both China Construction Bank and Agricultural Bank of China are amongst the 30 Global Systemically Important Banks.

So what we have here in the AML/CFT area is not an example of the law acting as it should – Blind Justice – but of laws that are applied or not applied, and of available penalties that are varied as regards severity and timing, in accordance with the offender and not the offence.

Instead the authorities make up their own mind – frequently behind closed doors - as to which banks to apply the law to and when, and which penalties to apply to a given situation.

There is significant recourse to extra-judicial processes like those that sit behind the Notices of FinCen, where the evidence is not made public and where the subject can only see it third-hand, by having a judge review the evidence in camera: neither the subject nor their legal representative can be present.

Since FATF itself acts as the ultimate court of arbitration by issuing – without contradiction - its Recommendations and Special Recommendations that lawmakers convert into laws and supervisory regimes, the entire edifice has gone outside democratic control. The edifice may claim to have been successful in reducing money laundering and blocking terrorist financing, but there is no factual evidence either in the form of a placebo test – what would have happened if FATF had never been established – or of a sanity test – what has actually been achieved and what could have been achieved by different means.

Instead we have the prima facie evidence that the crassest breaches by the largest banks can go unpunished, that other large banks are fined, supervised, fined again and the breaches continue, but that the roof is brought down on the smaller banks. That does not sound like an ecosystem in which money laundering and the financing of terrorism have been successfully eliminated, or one in which justice is blind to expedience and commercial prejudices.

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Could your Business Tolerate a Good Ending?

Proserv is a global leader with a worldwide presence, offering a fresh alternative in the delivery of engineering and technical services to the energy, process and utility markets. We spoke to Andy Anderson, Regional President MEA at Proserv, to find out more about the company and its innovative services.

A wave of new competition, new legislation, and a loss of loyalty, is impacting the financial services sector. To survive will require some radical approaches. One solution might mean visiting an issue that many businesses find repulsive.

Financial services current business model, assumes a single engagement between a provider and customer will last forever. But the business environment is changing around this model. Which now appears, too slow, too expensive, blind to the latest legislation, and fails to admit endings in the consumer lifecycle.

To survive will require adapting to multiple engagements with consumers over decades. In doing so will need to place long term consumer experience and brand equity over short term gains. Amongst this, businesses will start to value endings, an issue they have avoided up until now.

Financial services have for decades enjoyed long term customer loyalty that many sectors envy.

Before the 2008 crash, people changed their bank account, according to the UK’s Independent Commission on Banking Report, on average every 26 years. It found that 75% of personal current account holders had never switched.

The reasons for this loyalty, however, is not so flattering, with 1 in 5 people saying this was because of the hassle and potential risks of switching. Direct debits taking a while to move, and income not being able to stretch over the 30-day period that it sometimes took. Customers found it hard to end a service.

Banking still enjoys a historically low churn of 15% for long term accounts with stable loyal customers.

But, what is now emerging is the worryingly high

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churn rate of new customers. 20-25 percent within the first year. Half of which are leaving in the first 90 days.

This seismic shift will also disrupt the profit model of many businesses, not least the average bank.

To provide a US bank account relies on set-up costs of around $200. Online accounts a little less at $150. The break-even takes nearly 18 months to achieve. Which, given the current short-term churn trend, will dissolve profits.

Start-ups are leveraging new technology to challenge many established businesses. The Fintech space is expanding aggressively. Backed by significant funding - $14.2 billion of VC investment over 1,842 companies, according to the London Stock Exchange.

These digital native companies are more familiar with shorter loyalty periods of apps. Which can be as high as 76% worth of churn over 90 days. A terrifying prospect for a bank that relies on loyalty of years to make a profit.

Adjacent to these trends are changes to legislation in Europe and the UK. Open Banking and the GDPR regulation both require plenty of changes for businesses. More data protection for consumers. More expectations on providers.

And the overlooked aspect of more consumer empowerment to end a service.

Championed by many, Open Banking allows the consumer to expose aspects of their personal banking data to competitors. Aiming to open up the market for new competition. But, it also increases the likelihood of churn across industry, as people move more often with tempting offers.

GDPR’s Data Portability, achieves a similar result.

Allowing people to share data with other providers.

Additional parts of the GDPR law provide opportunity for consumers to halt services by removing consent. And even deleting all evidence that they even used the service through the Right to be Forgotten.

The single engagement model is dead. Loyalty is failing longevity. Technology rewards short term engagement. Legislation empowers endings.

Established providers in the Financial Services sector have good reason to worry.

The new model would see multiple engagements with the same customer over decades. Banks will need to become more agile. Individual engagements will need to be cheaper and quicker.

The two year break-even of a product will not work. Profitability will need to be achieved in three months. Products need to be as seamless to offboard as they are to on-board. Endings need to be positive and efficient. With the expectation of a customer returning in the future.

The ones who can’t survive long term will fail. A start-up on their first round of seed funding has limited ability to run a multiple engagement model, fought over years. Older, bigger banks have an advantage here.

But, the current psyche in business says endings are repulsive. Seeing it as a permanent relationship break-up. In the multiple engagement model consumers will be coming back and leaving often. As such, businesses need to value goodbyes as well as they value hellos. Requiring a cultural shift of some magnitude.

How do you design a good ending? These are the characteristics present in a good consumer ending.

Could your Business Tolerate a Good Ending?

It should be consciously connected to the rest of the experience. Through emotional triggers. That are actionable by the user. In a timely manner.

Joe Macleod

Consciously Connected For example, the consumer should have a similar branded experience at the beginning and end of the engagement. The same narrative voice should off-board them from the service, with similar principles and tone of voice as on-boarding them.

Emotional Triggers The emotional triggers that communicate benefits of a service should be repeated at the off-boarding. Providing an opportunity for the consumer to personally reflect on the experience gained while a customer.

Actionable The consumer needs to recognise stages of leaving. Acknowledging each one with clear actions. Installing personal responsibility in the process.

Timely Manner The desired efficiency required in the multiple engagement model should make off-boarding a seamless experience.

Business won’t have the luxury of delaying people’s departure from services. Heavy handed retention teams will need to be replaced with more strategic approaches.

The multiple engagement model won’t tolerate bad endings.

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Debunking Five Crucial GDPR Misconceptions With GDPR coming into force on the 25th May 2018, businesses that haven’t got to grips with the reality of the regulations risk massive financial penalties, together with possible reputational damage and detrimental effects on shares, according to Barristers-at-Law, Quentin Hunt and Dean Armstrong QC – co-author of Cyber Security- Law and Practice.

There’s now less than a month to go until the European Union’s (EU) General Data Protection Regulation (GDPR) comes into force, and yet research shows that many businesses are still struggling to understand what they need to do.

Worse still, many remain unaware of the full extent of the legal implications of non-compliance – whether deliberate or accidental. A YouGov poll in March found that 72% of British adults hadn’t even heard of the regulation, whilst a study by Crowd Research Partners carried out in April found that just 7% of companies worldwide were ‘fully prepared’ for GDPR’s arrival.

These figures should be cause for concern, since GDPR represents a huge change in the way in which every business uses, manages and protects personal data. It enshrines the sanctity of personal data ownership with the individual, with businesses merely the custodians. And as Jan Phillip Albrecht LL.M, Member of the European Parliament and Vice Chair of its Civil Liberties, Home Affairs and Justice Committee wrote in 2016: “It is paramount to understand how GDPR will change not only the European data protection laws but nothing less than the whole world as we know it.”

With this in mind, here are the five most common myths about GDPR, and some steps you can take to ensure you’re on the way to being geared up for the change.

This isn’t just about the EU One of the biggest misconceptions about GDPR seems to be that it’s only an issue for companies physically based in the EU. This is not the case.

GDPR essentially applies to any business anywhere in the world wanting to sell products and services to EU customers, or monitor their behaviour using personal data. In other words,

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if you’re based in Dubai wanting to do business with a customer in Germany, then GDPR – or equivalent standards – still apply.

It’s not as simple as following the rules One of the reasons why GDPR is causing a certain amount of angst – amongst those who have, in fact, heard of it – is that it is principle-based regulation, which means that judgement will be based on whether data has been processed in accordance with designated principles, rather than hard and fast rules. If a company is investigated by the Information Commissioner’s Office (ICO), then the ICO will look at whether ‘effective’ consent has been obtained by the data’s owner and whether that data is deemed ‘current’. This leaves the door open for interpretation, which would be entirely at the ICO’s discretion and involve a legal-based assessment. This means there’s a big job for the legal profession in helping businesses understand and act on their responsibilities.

It’s about more than just compliance The other source of confusion in all of this is that many companies have assumed that this is a compliance, or even a technical issue, which can simply be left to the relevant team to deal with. The problem is that GDPR is so allencompassing that any individual handling data in an organisation will undoubtedly require training to understand the regulatory demands and what to do in order to comply. It also means assessing processes for handling a serious data breach and examining every contract – with employees and subcontractors – to ensure that they are GDPR compliant. For some companies, it may also mean hiring a dedicated data protection officer or at the least gaining specialist legal advice on their current practice and system.

Technology is no panacea Likewise, GDPR is not something that can be ‘fixed’ with technology. A lot of people have mistakenly assumed that GDPR is only concerned with extreme data hacking cases, but the regulation imposes draconian sanctions for a range of other breaches, too. For example, if consent of use has not been properly obtained, or the data is not processed as set out in the regulations, then serious penalties, including hefty fines, could be on the cards. There are also some data breach risks that simply cannot be fixed by technology, for example a staff indiscretion or mistake such as leaving confidential information in a public place. What’s more, GDPR forbids reliance on automated decision making, as typically seen when loan companies refuse customers based purely on an automated credit score. The point is that this regulation demands that companies take a holistic and intelligent approach to the treatment of personal data – it’s not a question of picking and choosing the bits you want to adopt or relying on your systems to do the job for you.

This isn’t just another overhead It’s hard to overstate the risk of getting this wrong – the potential fines are on a level we’ve never seen before in data protection. Certain infringements are subject to fines of up to €20 million or 4% of worldwide annual turnover – whichever is higher. Severe breaches also run the risk of class actions. But the fines only tell part of the story. The Facebook/Cambridge Analytica privacy scandal wiped around £25 billion off the social media platform’s value in the first 24 hours after the story broke and the reputational fallout continues. Businesses simply cannot afford the reputational damage that could be wrought by such a significant change.

Debunking Five Crucial GDPR Misconceptions

Not sure if you’re in breach of GDPR regulations? Take the GDPR quiz to test your resilience.

Four things you should do straight away: 1.

2.

3.

4.

Review your processes for data breach notification, security and risk assessment.

Ask yourself whether the data you handle could be anonymised.

Review your contracts for GDPR compliance.

Consider hiring a data protection officer or seeking specialist legal advice.

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Explaining the Unexplained A tool with an international reach: an insight into Unexplained Wealth Orders. By Neil Swift, Partner at Peters & Peters What are UWOs? An Unexplained Wealth Order (UWO) is an order requiring a person to explain their ownership of a specific asset and how it was obtained. UK law enforcement agencies including the National Crime Agency (NCA), Serious Fraud Office (SFO) and Her Majesty’s Revenue and Customs (HMRC) have been given the power to apply for UWOs, which will be granted by the High Court if certain conditions are met.

UWOs can only be obtained against two categories of person: politically exposed persons (PEPs) from outside the EEA; and persons suspected of involvement in serious crime or those connected to them. The law enforcement agency will have to convince the court that there are reasonable grounds for suspecting that the person could not have obtained the property using their lawfully obtained income.

UWOs can be used in conjunction with interim freezing orders that temporarily prevent the recipient of the UWO from dealing with particular assets, for example by selling them or removing them from the jurisdiction.

The UK government has estimated that around 20 cases a year will involve the use of UWOs. The NCA, the UK’s law enforcement authority responsible for tackling serious and organised crime, is the first to make use of these new powers.

By February, it had announced the obtaining of two UWOs, as well as interim freezing orders, in relation to real estate worth around £22 million that the NCA believes to be ultimately owned by a politically exposed person from Central Asia.

A tool with an international reach UWOs have an almost limitless international reach.

An order can be obtained against an individual anywhere in the world.

For an UWO to be made against a person suspected of involvement in serious crime, the alleged criminal activity can have taken place anywhere in the world, provided it would constitute an offence if it had taken place in the UK. The property in relation to which an explanation is

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sought may also be located anywhere in the world.

Comments by law enforcement officials in relation to the first UWOs suggest a likely focus on UKbased real estate, in the context of significant political and media interest in the channelling of illicit funds through the London property market.

High value immovable property is an easier target for law enforcement agencies, particularly where the ultimate owner has a relatively modest publicly declared income.

However, the wide extra-territorial scope means it is possible that UWOs will be used to obtain information about the ownership of assets held in ‘offshore’ jurisdictions, including through trust or company structures.

Use of UWOs as a political tool The potential for UWOs to be used as a political tool is open to debate.

In the wake of the Skripal poisoning and heightened public concern about the activities of Russian individuals in the UK, members of parliament have already called for UWOs to be targeted against members of the Russian community whose wealth is thought to be attributable to their links to the current regime. NCA officials have been quick to respond that the power cannot be used to target particular nationalities and that they will always need to gather sufficient evidence to justify applying for an order.

It remains to be seen how the courts will react to any use of the tool that is seen to be overly politicised. On the one hand, the wide jurisdictional reach, coupled with a low bar of ‘reasonable grounds’ for doubting the lawful acquisition of the property, give law enforcement agencies scope to use this tool in a wide range of cases, and leaves judges with limited discretion to refuse to grant an order.

However, law enforcement agencies with limited resources will need to choose carefully when making use of this potent new tool and have various reasons for being circumspect.

They will be aware of the risk of challenges to

UWOs. UWOs are made without notice to the respondent, who is not able to be represented at the hearing, and this places an obligation on the law enforcement agency to provide full and frank disclosure of all the circumstances. Those who feel an incorrect or incomplete picture has been presented will be quick to challenge the UWO. Challenges on human rights grounds are also likely. An individual required to prove to the court that their property has been obtained through lawful means may argue that this constitutes a breach of their rights to property or to privacy, both protected by the European Convention on Human Rights. Law enforcement agencies will be anxious to avoid a finding by the UK appeal courts that this draconian measure is being employed in a manner that is disproportionate.

Law enforcement agencies will be alive to the wider geopolitical implications of targeting certain nationalities in their use of this new tool. It seems unlikely that they will be used against PEPs from countries with strategic importance for the UK or with which the UK government enjoys friendly relations. Foreign governments may be keen to encourage use of UWOs to supplement their own corruption investigations, and a law enforcement agency may decide to open an investigation and apply for an UWO because of information passed from a PEP’s country of origin. It has been reported that the Serious Fraud Office will seek its first UWO in relation to London properties owned by former Nigerian leaders having been alerted by current president Muhammadu Buhari. It will be for the law enforcement agency to decide how to respond to tip offs such as these, and it is hard to imagine that the relationship with the current regime will not be a factor.

Interestingly, one limitation on the international reach of UWOs is the somewhat arbitrary distinction in relation to PEPs. The power to make an UWO against a PEP only applies to individuals from outside the EEA. Public officials and persons connected to them from European countries with consistently high rankings on corruption indices, including Romania Hungary, Bulgaria are therefore completely excluded.

Explaining the Unexplained

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Mapping the Surge in Popularity of the Tier 1 Investor Visa Since the vote to leave the EU in June 2016, the thorny issue of immigration has dominated public and political discourse in the UK. However, a recent surge in the number of applicants for Tier 1 investor visas has provided positive reassurance that countries overseas still have faith in the UK economy and consider the British Isles a suitable place both for relocation and for the investment of their funds.

While it has operated since 1994, in 2004 changes were introduced around the regulations and application process for the Tier 1 investor visa, which largely flew under the radar. However, when the UK points-based immigration system was introduced in 2008 and a concrete set of requirements were implemented around the previously-subjective Tier 1 visa, high-net-worth individuals and private investors from across the world began to realise the scheme was in place and started taking advantage of the benefits it could bring.

In order to be eligible to apply, individuals must have £2 million or more of their own money, held in one or more regulated financial institutions, which is disposable in the UK, along with a UK bank account. Investing this lump sum of funds allows a visa to be granted for an initial period of three years and four months, which can be extended. After five years the individual can apply for ‘indefinite leave to remain’ in the UK, otherwise known as settlement. Depending on the amount invested, the time period after which indefinite leave can be applied for is shortened; for example, investors bringing £2 million can apply after five years, those investing £5 million after three and those bringing £10 million or more after two. The applicant can also bring a spouse and any children under 18 years along with them as dependents.

Gaining indefinite leave to remain is very similar to citizenship. Individuals are able to access many of the same rights as UK citizens, including education and healthcare, however they do not have the right to vote. If citizenship is ultimately the end goal for any Tier 1 applicant, the option to apply for this further down the line is there, if residency requirements are met. Additionally, it is worth noting that anyone holding indefinite leave

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to remain who exits the country for more than two years will lose their status.

Since its introduction, the Tier 1 investor visa has experienced waves of popularity, partly in response to changes to its specific requirements, and partly due to global geopolitical issues. In late 2014 the Government announced the minimum amount for investment would be raised from £1 million to £2 million, prompting a huge surge in the number of applicants ahead of the changes being introduced.

However, following a sharp decline in 2015, figures for recent years show that the number of applicants is once again on the increase.

In the final quarter of 2017, the UK Government issued 81 Tier 1 visas, 32 per cent more than in the same period in 2016. Whilst this acts as a useful indicator that foreign investors still remain confident in the future success of the UK economy, it is also interesting to see where these wealthy individuals are coming from. Whilst 60 per cent of those visas issued were to individuals from China and Russia – typically the two countries with which the scheme is most popular – there were also increases in the number of applicants from Turkey, Iran, the USA and Canada.

The locations of these countries demonstrate the varying reasons why the Tier 1 scheme is so popular. Particularly in the Far East, the scheme is often viewed as a fast track scheme into UK higher education, with families gifting their children lump sums for investment. For students, the benefits of not being on a student visa means that after courses are complete and qualifications have been secured, the Tier 1 visa allows them to apply for indefinite leave to remain, without negotiating the standard immigration channels. For other countries around the world, the UK is still seen as a more

stable investment option and for them, applying for the Tier 1 visa forms part of a move to seek more economic certainty.

Whilst the benefits of the scheme are clear, there are some considerations that potential applicants must bear in mind when taking this route. Holding a UK bank account is a requirement for eligibility and whilst there are many institutions which offer the global reach to make this a possibility, the process is not always straightforward and can take some time, so setting this up well-ahead of beginning the application is advisable.

Additionally, by their nature, many high-networth individuals are globally mobile and often tend to travel for a large percentage of the year, conducting their business around the world. One condition of getting indefinite leave to remain through the Tier 1 scheme is that you remain a resident in the UK for six months of every year, for individuals who travel a lot, this must be taken into account.

Whilst the application process itself isn’t onerous, individuals would be well-advised to seek specialist wealth planning, tax and legal advice well in advance. Many wealth managers are Tier 1-compliant and will be able to advise on where investment can and can’t be made to meet eligibility criteria and to what extend investment returns will be subject to tax. For example, it is useful to know that investments in property are not permitted as part of the scheme.

The growth in popularity of the Tier 1 investor visa should be comforting news for the UK as increasing inward investment and the knowledge and talent that goes with it is a clear sign of the health of the economy. For wealthy individuals

Mapping the Surge in Popularity of the Tier 1 Investor Visa

around the world who are looking to move to the UK, this visa offers global mobility and a fast track route to life in Great Britain.

Tijen Ahmet is a business immigration specialist at law firm, Shakespeare Martineau.

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32 Wealth & Finance International - Issue 5 2018