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All banks suffer outages sadly. Resilience is uber important but what is equally important is how you deal with issues, how transparent you are and your customer communications.....

It's interesting as to get into crypto assets there is an on and off ramp - based around FIAT currency. Many assets are backed by a FIAT so you would think the impact there would be neligble since ultimately a bank holds that FIAT. The wider issue will be when crypto assets obtain a FIAT value and there was no on ramp using FIAT. 

Crypto must be regulated like all other assets that are bought and sold. The issue here is that central banks and regulators are slow to understand the mechanics and the value - which I personally find odd since the vast majority of FIAT has been virtual/digital for decades....

When Nick Ogden and myself sat down to define what a modern clearing bank (agency banking provider) should deliver, we coined a phrase, Banking-as-a-Service back in 2014. The principles were simple, enable others to utilise banking capabilities as if they were the bank. Provide banking capabilities but in a highly de-constructed fashion, allowing customers to subscribe to the modules that they require, not necessarily all of them, only those they require to build their propositions. Make sure you have a cloud architecture and platform to deliver infinate scale because you simply need to grow with your unknown number of customers, and their unknown number of customers and the demands these unknowns place on your solution.

BaaS is a fantastic opportunity for those that have the banking capabilities, but as a warning, it is only a fantastic opportunity for those with the correct architecture in order to support it, ensuring customers do NOT get a second rate experience.

Though BaaS represents $7 trillion opportunity, it really will only work well for those banks that have invested heavily in ensuring they have the right IT capabilities to deliver a true BaaS solution.

The UK has done a great job in pushing Open Banking forward. The challenge now is expanding its appeal to us the customer, while also expanding into the world of Open Finance. 

The big challenges though are still there, costs for the banks, ensuring the banks infrastructure delivers open banking experiences which are in-line with customers coming directly to the bank. Here challenger banks architecture, or those banks that utilise a mature BaaS play, have a massive advantage, since they follow more modern IT architecture patterns.

But this will not be enough. Modern IT system (brought about by Cloud principles) don't have direct API connections between entities or domains. Yet here, we are actively promoting an approach which is now quite dated, adds massive overhead from a technology point of view (testing, maintenance, version control) that all adds costs. The approach also doesnt truely put the customer at the centre of the experience, after all the customer is handing out access tokens to third parties, which are directly communicating with each other at that point - when really the data should be flowing through me, the user. 

Open finance has to start embracing event based models, models that are driven by the customer themselves - only then will we be able to move to a simplified and yet immensinle more powerful Open Banking and Open Finance world.

Kill APIs if we want Open Finance – FinTechAndrew – The blog (wordpress.com)

I totally agree with this post. 

What I would add is, technology as its role to play, and CDD needs itself to be looked at. Banks are not the custodians of an individuals personal data, or a corproates data, the person or corporate owns that. CDD is therefore all about risk, not the underlying datagathering. 

I strongly believe that true digital identity solves most of these challenges for banks, it significantly improves KYC accuracy and removes many of the cumbersome steps that we aassociate with KYC. It also aids compliance, especially around GDPR and ultimately delivers a significant improvement in customer experiences our outcomes.

The banks that adopt digital identity and embrace it early, will reap the rewards with their ability to attract new customers, but to also ensure they reduce associated risk and significantly improve their compliance....That's before we mention ongoing CDD, which digital identity solves totally for banks too...

Sadly these breaches highlight infrastructure challenges for these banks, and shouldnt be seen as something they maybe doing on purpose. 

When you have multiple sources of data being shared across platforms and to various different consumers of that data, you have to have a resilient event driven model. Direct APIs are not the way to go, they are complex and put a large overhead on the bank. 

Sadly these issues should also be taken into consideration when we talk about expanding open banking concepts to open finance. We cannot implement in a similar direct API fashion, because the burden will just become too much. Open finance must start to embrace the concepts of event models and event subscriptions...

Kill APIs if we want Open Finance – FinTechAndrew – The blog (wordpress.com)

The reality is, the only time you need a "multi-cloud strategy" is when one cloud provider does something fundamentally better on a specific product. In such a case, Cloud should be thought of as a provider of technology, especially since interconnectivity between cloud providers is so easy to achieve. 

You should not be thinking multi-cloud for core operations or for failover, if you are, you are not understanding the high availability models that clouds operate. Sure you can implement it if needs be, but the cost of doing so, then maintaining that strategy over time and alongside the ever increase pace of evolution on each cloud is simply nuts, especially given the actual risk of a total outage.

Obviouisly countries like Russia will set up technology that enables them to potentially comunicate with banks off of SWIFT rails. This shouldnt be seen as a surprise or a threat (maybe a threat to SWIFT but thats all). This is because they still need a bank to correspond with/partner with the other side of those communications. The "way" in which they communicate is totally irrelevant - western banks will still have to follow their regulaotry obligations, therefore their countries sanctions lists. 

Clearly if they build their own rails then they are able to communicate more freely with those banks that still elect / are able to do business with sanctioned banks. But if that's the case, they are probably still communicating what they wish via the good old telephone or email...

Why only the CEO? Why not the entire ExCo, well those that knew what was going on....

This drives me nuts. SCA is for sure needed, it will protect many of us from typical fraud scams. However, the impact on the customer experience will also ensure many of us will drop out of our shopping carts and ultimatly, that results in loss of sales and frustrating experiences for consumers.

If only regulators and the financial services industry would look to more innovative solutions, yes you may struggle to understand them at first, but there are much better models and solutions for delivering security online. It's time we really looked at these models, most of which are possible because of digital identity. 

The current crop of security solutions will soon prove to be the diesel car or the mini-disc approach....