But David, neither have many of the senior staff at the PSR, all but three of the NPSO Board, or any of the NPSO End User Advisory Council ever worked in the payment industry as we would define both the "payment industry" and "work" (i.e. carry out tasks rather than sit as a NEDdie or as a trustee, audit the work or consult about it).
They command a combination of knowledge on the subject which is modest given the importance of the tasks assigned to them. We are talking Premier League tasks but a squad composed of All Stars from various other sports that would struggle as a unit to progress in the Johnstone's Paint Trophy.
This is emblematic of the new world and its new Establishment. In Ms Hogg's case it is the career path through Harvard and McKinsey and directly into the C-Suite of an industry vertical in which she had never done the work herself that the oily rags do. At Lloyds Bank International a graduate trainee, even one with an Oxbridge First, did not progress into management without carrying out every job in the bank, from mail room, messenger, telex clerk, test keys, mail transfers, nostro recs, cash desk, upwards.
At least we have one forum where the new Establishment can be held to account in public, and frankly I am not too fussed who represents Joe Public in the TSC as long as they get properly stuck in.
The analogy with the rail network or Student Loan Company does not seem to me to fit the bill. I would go for the power supply to an intensive care unit. Visa is a creation of the payments industry and of its successful efforts to make cards ubiquitous, do payments in near real time, and displace cash and cheques. Visa must accept the other side of the same coin: it has become a critical service and so it must have Five Nines availability. It has failed to meet the correct standard and a head must roll.
Since it is a regulated UK payment system, the regulator has also failed and a head should roll there as well.
07 Jun 2018 09:25 Read comment
This is all fabulously interesting and just a small question, if it isn't too much to distract you from your important tasks on innovation, diversity and all the other good stuff you have mentioned, and I apologise profusely in advance for disturbing you during such an important industry event.
It is because my daughter is soon going to Croatia, and my wife and I to Iceland (where there aren't any ATMs, be they free to use or involving a fee, or "at risk" to use the PSR's new terminology, or anything else), and one of my sons works at an adventure centre in the Scottish Highlands (where the local banks have considerately axed all ATMs within a 30 mile radius).
We are all totally dependent upon Mastercard and Visa, and their having 100% availability in the European region.
As the President of Mastercard in the region, can you provide a categorical assurance of 100% availability?
If you cannot, then I suggest you seek a different position, likewise if you give the assurance and then it turns out not to be true.
05 Jun 2018 18:58 Read comment
A "headlong rush" would be reminiscent of the Gadarene Swine (Mark 5 verses 1-20), where the pigs into which Christ had exorcised the demons hurled themselves over a precipe: a perfect analogy.
A "Flucht nach vorne" occurs in "Death in Venice" I believe, if only I had my copy with me to check, where Aschenbach feels impelled towards Venice to escape the demon of a collapse of his creative activity, an activity deriving from a corruption below the surface and obscured by his well-crafted public persona of bourgeois respectability.
The impulsion to Venice is a death wish. When typhoid breaks out he consumes infected strawberries instead of leaving: this sounds like the UK's Remainers as well as the adherents of The Project at the European Commission.
22 May 2018 12:55 Read comment
The bit of this that I find particularly underwhelming is that "the leg of the transfer that touches the XRP Ledger only takes 2-3 seconds with the additional processing time happening while the transfer moves across the intermediary digital asset exchanges and local payment rails". 2-3 seconds is slower than SWIFT MT, and SWIFT payments also have to go across "local payment rails" but do not need to go through any "digital asset exchanges". SWIFT Global Payments Initiative can cut the end-to-end timing to minutes if the banks in the respective payment chain are geared up, and if they aren't geared up for SWIFT payments they won't handle any Ripple payments that come to them along the "local payment rails" any quicker.
11 May 2018 15:25 Read comment
This is all most beguiling and does not say whether all the Virtual Accounts are numbered in a way that is identifiable to the exactly same Account Servicing Institution as the single, actual account. If the actual account is at BAML in the UK, then all the Virtual Accounts should be identifiable to BAML UK too, and not to BAML branches and subsidiaries in other countries, or to BAML partner banks. If, though, the Virtual Accounts are identifiable to different ASIs (inside and outside the BAML group), and payments are flowing into and out of those Virtual Accounts without express mention of the actual account, then there is a very interesting debate about FATF Recommendation 16. Likewise if the Virtual Account is identifiable (through the unique bank details issued to the user client which they put on their invoices) to a different financial institution than the one holding the actual account, an Account Servicing Institution can be deemed to have been established, requiring Customer Due Diligence to the same level as a real account. I will shortly be sending a paper to the Wolfsberg Group about their Payment Transparency Standards 2017 insofar as they address what they call On Behalf Of set-ups (to which Virtual Accounts are closely intertwined). In the putative example that I use in the paper, there are multiple breaches of FATF Recommendation 16 and many instances where a CDD file is missing. It is based on my experience of the usage of Virtual Accounts by a major bank headquartered in the USA to service a Shared Service Centre and the Operating Companies in the same group, where the OpCos all get local IBANs or BBAN+Routing Code, but only the SSC has to send a CDD file and then only to the bank arranging the scheme.
07 May 2018 19:12 Read comment
And of course the person in question is conflicted by being a NEDdy of NPSO at the same time as owning it. Indeed, as Jonathan indicated above, this NEDdy is the one who has been hired to manage risk. "Physician, heal thyself" (Luke 4.23).
02 May 2018 16:00 Read comment
As a natural legal person the individual does not even satisfy the Eligibility Criteria on page 7 of the NPSO's Articles of Association to be a member-guarantor in the first place: as a result the grounds for removal stated in Part 3 para 26 are designed for a corporate member-guarantor and do not even include the normal ones for a natural legal person such as death and being sectioned under the Mental Health Act. The only leverage would come where, in the opinion of NPSO's Board, the individual was not acting in the best interests of NPSO. This determination would then kick off a process in which the member-guarantor has a right to protest. Anyway, the key point is that having a natural legal person as a member-guarantor of NPSO conflicts with the Eligibility Criteria. It is worrying that the dozen or so NEDdies and the NPSO's supervisors (the PSR and the Bank of England) don't seem to have picked up on this. Even if the member-guarantor wants to withdraw, there is a 3-month notice period.
02 May 2018 11:21 Read comment
Totally agree. Now the Post Office won't collect cash at merchant premises, cash deposit has become a Top 4 issue in UK payments, alongside access to free cash withdrawals because of branch closures (the other two being high deductions from merchants' card proceeds and Authorised Push Payment fraud). It's a pity that only one of these falls within the self-circumscribed scope of the new power complex of Payment Systems Regulator, Payment Strategy Forum, New Payment System Operator and New Payments Architecture, and even then not in a good way - their plan is to settle all payments via Authorised Push Payments, thus promising a fat payday for the scammers.
27 Apr 2018 17:50 Read comment
23 (vingt trois) is the new Magic Number... of points in the EC FinTech Action plan, of stab wounds suffered by Julius Caesar, of Russian diplomats expelled by the UK, of UK diplomats expelled by Russia. Is this a secret signal to alien space craft?
18 Mar 2018 10:20 Read comment
According to LinkedIn there are actually three Jean-Yves Rotté-Geoffroys, or rather three-in-one, two parts of the trinity being based in Sao Paolo and one in London, omnipresent, everywhere and nowhere, baby, flying across the country, wearing which hat is it today? I won't make a fuss though it's obvious...that this may be enough to skirt round the Non-Resident Director issue, and that is a silver lining.
10 Mar 2018 11:26 Read comment
Julian HensmanConsultant at seOrb
Michael Mcdowellconsultant at Sapphire Capital Partners
Jean SeryConsultant at GFI
Akshay GoyalConsultant at Abrantix
Hisham AhmedConsultant at Malomatia
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