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    Compliance, Technology & Innovation

    Glenn Seah, Managing Director And Head Legal, Compliance And Corporate Secretariat, Singapore Exchange

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    Glenn Seah, Managing Director And Head Legal, Compliance And Corporate Secretariat, Singapore Exchange

    We live in exciting times, when innovative ideas and technology capabilities are converging to promise quantum improvements in the way that we live and work. In the compliance world, ‘Regtech’ and ‘Suptech’ are now popular buzzwords, and for good reason. The question is, will compliance functions ride this new wave, or be left behind?

    Mistaking technology for innovation

    The story is told of a young man who climbed up a mountain to consult the wise mystic who was said to live near its peak. When he finally meets the wrinkled old man sitting peacefully under a gingko tree, he asks; “O wise Master Ayumu, why do people think all millennials are the same?”

    To which the old man replies, bemused, “I’m not Master Ayumu!”

    When one thing is repeatedly associated with another, it is easy to forget they are not necessarily the same thing. Just because an old man is sitting under a gingko tree on top of a mountain doesn’t mean he is a guru. In the same way, technology can often be conflated with innovation. In these heady days, technology can even be frothily equated with success in general, as companies scramble to label themselves with AI-this and blockchain-that.

    In his book Good to Great, Jim Collins calls technology an accelerator. To paraphrase; technology, in and of itself, does not create value or innovation. Rather, technology accelerates value-creation or innovation. But when badly applied, it equally amplifies wasted effort or even paralysis.

    If we regard technology itself as the solution, the underlying rationale can be lost. One recent example is the faddish obsession to put just about anything on a blockchain, whether or not a distributed ledger actually adds value. Another example is using technology to automate what is fundamentally an unsound process. This could lead to faults being hardcoded and problems magnified, while ironically reducing human ability to adapt and intervene.

    It is easy to mistake technology itself for innovation. However, when applied well, technology can transform business, eliminate human error, improve consistency of judgment and, potentially, self-improve through machine learning.
    Can innovation co-exist with rules and processes?

    As a market operator and regulator, Singapore Exchange (SGX), believes in effective regulations that facilitate fair, orderly and transparent markets for our customers. At the same time, we embrace innovative technology that creates a more efficient and seamless platform for our customers to invest and manage risk. It is this convergence of nimble, intelligent and effective rules and platforms that enables us to be consistently recognised by the industry as a market leader.

    Yet, the association of regulation and processes with bureaucracy can mean that, just as technology is sometimes conflated with innovation, compliance and regulatory processes can be conflated with non-innovation. There seems to be a misconception that process is the antithesis of innovation. In a world enamoured with “move fast and break things”, process has become a dirty word.

    The unglamorous truth is that innovation often works best in conjunction with process. Innovation without process and purpose is mere trial and error. On the other hand, innovation with guardrails is directed ingenuity, with accountability for results.

    Re-imagining compliance processes

    The compliance function, with all its rules and processes, is ripe with potential for directed technological innovation. Many compliance processes have, over the years, gone through the crucible of refinement and are prime candidates for automation, because good processes make for effective automation.

    One example is in the sphere of anti-money laundering, where manual searches and first-cut analyses are increasingly replaced by machines, thereby reducing error and introducing relentless consistency.

    In fact, automation is no longer confined to mere “doing”, and has extended to “thinking”. It is now de rigeur for compliance systems to employ “fuzzy logic” to identify patterns and deviations. Many technology solutions promise the enhanced ability to intelligently identify risk hotspots and unusual activities, and even learn to adapt to changing conditions.

    And there is more beyond the automation of “doing” and “thinking”. Technology, coupled with data, has given compliance functions the opportunity to not only make existing processes more efficient, but also to re-imagine processes altogether.

    Data analytics is the prime example. Let’s consider compliance testing as an example of this. Compliance functions typically conduct a comprehensive risk assessment exercise whereby it consults the business and other stakeholders through a number of meetings or workshops. Based on that assessment, the function will conduct various reviews to test organisational compliance with rules and regulations. However, with the right data, this process can be re-imagined. With swift and intelligent data analysis of breaches, audit findings, new regulations or customer complaints, a plethora of meetings and brainstorming sessions could be replaced, or at least dramatically augmented.

    Data analytics could also reduce the need for traditional periodic, sample-based look-back reviews. With the right data, exceptions and deviations can be picked up in real time, not only facilitating swifter organisational intervention, but also dispensing with significant time and effort associated with face-to-face compliance reviews.

    We live in a world that is governed by labyrinthine rules and regulations, and compliance functions play the critical role of “jungle guide” to navigate the morass of dos, don’ts and maybes. In the old days, guides relied on the sextant and astrolabe. Today we cannot imagine a life without the wonderfully intuitive Google Maps. What type of compliance guide will we choose to be for our companies? The opportunity is ours to lose.
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