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The regtech technology development, in the banking and finance sector, in Vietnam 2022
THE STATE BANK OF VIETNAM BANKING UNIVERSITY OF HO CHI MINH CITY GRADUATION THESIS THE REGTECH TECHNOLOGY DEVELOPMENT IN THE BANKING AND FINANCE SECTOR IN VIETNAM Major: FINANCE – BANKING Supervisor: Dr NGUYEN MINH NHAT Student: HUYNH THI NGOC ANH Student ID: 030805170278 Class: HQ5 – GE08 HO CHI MINH CITY - 2022 THE STATE BANK OF VIETNAM BANKING UNIVERSITY OF HO CHI MINH CITY GRADUATION THESIS THE REGTECH TECHNOLOGY DEVELOPMENT IN THE BANKING AND FINANCE SECTOR IN VIETNAM Major: FINANCE – BANKING Supervisor: Dr NGUYEN MINH NHAT Student: HUYNH THI NGOC ANH Student ID: 030805170278 Class: HQ5 – GE08 HO CHI MINH CITY - 2022 RESEARCH GUARANTEE I hereby declare that this thesis is my own research work The thesis with the topic " THE REGTECH TECHNOLOGY DEVELOPMENT IN THE BANKING AND FINANCE SECTOR IN VIETNAM " was carried out by the author under the guidance of Dr Nguyen Minh Nhat The research data in the thesis is compiled by the author from many different reliable sources such as: State Bank, Vietnam science and technology magazine Once again, I hereby declare that the content of the thesis published below has not been made without unauthorized copying of anyone else's research At the same time, this thesis has never been published in any form or used to defend a bachelor's degree at any university before The author guarantees that the research results of the thesis are independent and truthful I hereby declare and fully accept Supervisor The Author Anh i ACKNOWLEDGMENTS In the past time, thanks to the favorable conditions of Banking University of Ho Chi Minh City, I would like to thank all the professors at the university for having conveyed me a lot of useful knowledge and experience over the past fouryears, especially Ph.D.Nguyen Minh Nhat - the instructor who has wholeheartedly instructed me to complete this thesis well Last but not least, I express my deepest gratitude to my parents for teaching me everything that makes me who I am today Furthermore, I am grateful to my mother for her close support and encouragement throughout this study I wish you all health and success in the career of growing people Best regards The Author A ii PICTURE LIST Figure 1: Need of RegTech Figure 2: RegTech investments over the years Figure 3: Some technologies supported by RegTech Figure 4: Benefits of reporting tools Figure 5: Some benefits on the World 12 Figure 6: RegTech market segments – proportion RegTech solutions used by Fis 16 Figure 7: RegTech solutions that financial institutions have experience with and areas where RegTech providers offer their services 17 Figure 8: RegTech market segments – proportion RegTech solutions offered by RegTech providers 17 Figure 9: Year of RegTech solution going live first (left) and number of financial institution clients 18 Figure 10: Main effects of using RegTech solutions 21 Figure 11: The key reasons to implement Regtech 22 Figure 12: The main reasons using RegTech 23 Figure 13 : Learning machine 25 Figure 14: Obstacles and operational challenges per RegTech segment 33 iii ABBREVIATIONS AI Artificial Intelligence CEO Chief Executive Officer CFO Chief Financial Officer CIO Chief Information Officer EBA European Banking Authority EEA European Economic Area FLs Financial Institution Information & Communication ICT Technologies IA Internal Audit RPA Robotic Process Automation AML Anti – Money Laundering CFT Counter – Financing Terrorist AISP Account Infornation Service Provider iv TABLE OF CONTENTS TABLE OF CONTENTS v ABSTRACT CHAPTER : OVERVIEW OF REGTECH 1.1 Rationale 1.2 Features of RegTech 1.3 Some kinds of RegTech products 1.3.1 Report automation tools 1.3.2 Robotic process automation 1.4 The Difference Between RegTech, FinTech, and SupTech 1.4.1 Some basic things about them 1.4.2 RegTech is the regulator of Fintech 11 1.4.3 RegTech can support your organization to achieve compliance 11 1.4.4 Research results 13 CHAPTER : THE REGTECH TECHNOLOGY DEVELOPMENT IN THE BANKING AND FINANCE SECTOR .16 2.1 Effect of RegTech in the banking and finance sector: 16 2.1.1 Current RegTech landscape in the EU: 16 2.1.2 Monetary Authority of Singapore (MAS) 19 2.1.3 Financial Conduct Authority (FCA) 19 2.2 Challenges in using RegTech in Finance sector 20 2.3 Technologies trends in RegTech development 24 2.3.1 AI and machine learning for identifying and predicting risks in RegTech 24 2.3.2 Blockchain for automating compliance procedures: 26 2.3.3 The important role of regulatory bodies in the RegTech ecosystem: 27 2.3.4 RegTech firms must understand that that their role far exceeds technological innovation: 27 2.3.5 Regulatory Sandboxes as a Testing Ground for RegTech 3.0 28 v 2.4 The RegTech technology development in the banking and finance sector in Viet Nam………………………………………………………………………………29 CHAPTER : PROBLEMS AND SOLUTIONS OF REGTECH IN FINANCE SECTOR 31 3.1 Challenges of Using RegTech 31 3.2 Solutions for RegTech technology development in the banking in Viet Nam ……………………………………………………………………………………………….36 3.3 Conclusion…………………………………………………………………………35 REFERENCES .38 vi ABSTRACT The use of advanced technology in the financial sector continues at a rapid pace RegTech, is defined as any application of technology that supports innovation for regulatory, compliance and reporting requirements performed by a regulated organization (with or without support) RegTech provider support, potentially making compliance more efficient in the financial sector Financial institutions using a RegTech solution highlight enhanced risk management, better monitoring and sampling capabilities, and reduced human error as key benefits of using the tools Meanwhile, RegTech vendors highlight the ability to increase efficiency, quell the impact of constant regulatory change, and improve efficiency as key benefits associated with using our RegTech solutions However, RegTech solutions, if not implemented properly, can pose risks to FIs that need to be identified, monitored and managed These risks may relate to, for example, compliance, centralization, business continuity, ICT and security, reputation, internal governance, consumer protection, or technology At the same time, RegTech may present new risks to authorities monitoring FIs using RegTech solutions In particular, potential risks may arise when trying to assess the effectiveness and reliability of the technology solutions used by FIs, and there may be a lack of skills and tools needed to monitor technology For example, use tech-enabled RegTech solutions when trying to test underlying algorithms Therefore, a balanced approach is needed to acknowledge the benefits of RegTech and create an environment that supports innovation, but at the same time close supervision and a willingness to manage any associated risks CHAPTER : OVERVIEW OF REGTECH 1.1 Rationale Regtech concept The Financial Services industry has long been full of regulations In an effort to reduce the growing burden of these regulatory provisions, financial institutions are beginning to turn to new technology solutions Around the world, regulatory changes in the financial sector are accelerating at an astonishing rate Dealing with the high volume of new regulatory changes poses a high level of complexity and rigorous timelines for financial institutions Over the past decade, regulators have asked financial institutions to undertake some of the modernization of their businesses, and many have struggled with regulatory transformations Regulatory Technology (RegTech) has established a strong foundation in the FinTech ecosystem to overcome this and deliver solutions that target new and complex regulations, litigation and remediation areas faced by financial institutions (FIs), combined with an overall reduction in compliance costs There are more than 1600 companies worldwide, offering a variety of solutions and services to help other businesses meet their compliance needs Most of these companies help with regulatory compliance like PSD2, MiFID II, 4MLD and GDRP.2 And most of these RegTech solutions are available using open APIs and SaaS models Figure 1: Need of RegTech Nguồn: Needs Of Regtech | FinTech Insights | PwC's Financial Services analyze these data sets so that informed and timely decisions can be made and appropriate actions taken When it comes to RegTech, they have to contribute to an ecosystem that goes beyond the underlying technology itself To lead the digital compliance solutions they are seeking to promote, RegTech companies must develop a key understanding of the underlying needs of financial institutions, regulators and their advisors One such example of a transnational collaborative approach is the Asia-Pacific RegTech Network, which includes founding members from Australia, Japan, Hong Kong, Singapore and Malaysia, among others Another often overlooked stakeholder within the RegTech ecosystem are professional services companies By developing a better understanding of the needs of financial institutions, the requirements of regulators and the potential of RegTech solutions, professional services firms can bridge the ecology system gap and help all parties 2.3.5 Regulatory Sandboxes as a Testing Ground for RegTech 3.0 Sandboxes are virtual environments used to test and test the impact of innovative new processes or technologies in isolation The UK's Financial Conduct Authority (FCA) has been leading progress in this area, with its Innovation Projects unit announcing that the sandbox is a ―safe space in which businesses can test innovative products, services, business models and delivery mechanisms without immediate exposure to regulatory consequences of engaging in the activity in question The FCA Sandbox has three core goals: (1) to reduce time to market, (2) to improve access to finance, and (3) to encourage innovation FCA has been at the forefront of developing a structured and robust framework for effectively testing innovative financial products and services Such regulatory sandboxes show great promise in supporting the future growth of RegTech For example, economic analysis and agent-based modeling techniques can be used to simulate the actual impact of proposed new policies At the same time, although the term sandbox may seem novel in the financial services context (and actually has its roots in computer 28 science), the growing use of simulation, stress testing, and war games becoming commonplace among financial regulators and market participants — and we would describe all of this as ―sandbox‖ activity in the RegTech space Indeed, such techniques have been widely used in analyzing the potential effects of regulation by the BIS (Bank for International Settlements) and the Basel Committee These agencies have developed quantitative impact studies at the international level, in addition to economic analysis of the impacts of regulators in individual jurisdictions But there is potential to extend these approaches more broadly, with the area of conceptualizing consumer interactions perhaps the most challenging In this respect, efforts in the social sciences to design human experiments, as well as in the pharmaceutical industry, yield important lessons 2.4 The RegTech technology development in the banking and finance sector in Viet Nam According to the Bank for International Settlements (BIS) and the International Financial Stability Board (FSB), SupTech and RegTech can provide important benefits to supervisory regulators, financial institutions, and financial institutions and financial system stability A recent survey by the State Bank in June 2021 for 47 credit institutions (mainly banks) showed that about 35% of credit institutions have a good understanding and have applied the solution RegTech law; 10.8% have a medium level of knowledge and already have a RegTech application development plan; 27% understood the concept of RegTech and had a discussion about RegTech application at a credit institution The rest (27%) either not have the concept of RegTech, or not have any specific development plan The number of supervisory agencies with RegTech development strategies increased from less than 5% in 2016 to nearly 30% in 2020; The amount of investment in the RegTech sector tripled from $1.2 billion in 2017 to $3.7 billion in 2018 and to nearly $6 billion in 2020 29 Chapter Summary New technology can help regulators and priorities reset regulation, rethink strategies, and help ease the burden of compliance The purpose of the article is to continue the discussion and debate about the evolution of the RegTech field and to provide a way of assessing ongoing progress It will allow both the public and private sectors to consider the capabilities needed to achieve trust in the digital age The analysis shows that the field has made tremendous progress in a very short time and that although there are barriers, there is often a view on how to overcome them As the industry evolves after this most recent crisis, it will be important to recalibrate and refocus efforts on building a collaborative community with a sustainable and scalable approach to provide reliable solutions 30 CHAPTER : PROBLEMS AND SOLUTIONS OF REGTECH IN FINANCE SECTOR 3.1 Challenges of Using RegTech FIs face a number of challenges in risk management, illustrated below By partnering with RegTechs, whose expertise and open architecture, they can be better prepared to handle these uncertainties Implementing RegTech solutions to assist FIs in meeting their regulatory requirements efficiently and effectively is not without challenges The main challenges facing FIs revolve around six key areas: Data-related challenges and cybersecurity threats - data-related obstacles and most important obstacles There are often a number of issues such as data quality, data privacy and protection, lack of data integration, data availability, and lack of data standardization and harmonization These challenges become relevant to varying degrees in some use cases, e.g when you try to leverage internal or external data, financial or 31 non-financial data Data-related obstacles also include cybersecurity threats that are increased by the interconnectedness of different RegTech solutions and legacy systems used Not surprisingly, data-related challenges and cybersecurity threats can be significant barriers that can prevent the adoption of RegTech solutions Overall, be aware of personal data processing requirements and domain-specific requirements as the most important legal and regulatory obstacles Interoperability and integration with existing legacy systems - there are too many legacy FI systems and processes that make it difficult to adopt RegTech, and this is combined with a 'lack of confidence in the capabilities' of FIs' ICT infrastructure to be able to support FinTech, RegTech In addition, RegTech vendors are considered specialized but FIs generally prefer to adopt broad end-to-end RegTech solutions that can cover as many aspects of compliance as possible As a result, integration issues with legacy infrastructure are seen as a relevant obstacle across all RegTech segments Regulatory changes – changes to national or international regulations and other regulatory challenges can be another major barrier to RegTech adoption It is clear that for some FIs, the lack of clear rules and regulations as well as the lack of common positions of regulatory and supervisory bodies can be an obstacle to RegTech adoption In addition, the complex and constantly evolving legal landscape of national and international laws and regulations is also seen by some as a challenge For example, while there are a number of RegTech regulatory horizon scanning tools available, in many cases FIs use a manual regulatory tracking process to identify and evaluate relevant changes and their effects toward their impact on RegTech solutions RegTech solutions that have been used must be tested to determine if they should be adjusted in light of any new regulation, while any new RegTech solution or functionality can support FIs and reduce the burden of regulatory changes Lack of necessary skills and training – when working with internal or external RegTech solutions, FIs need experts, e.g data scientists and engineers, to be able, if relevant agencies, to find, evaluate, operate, and maintain up-to-date RegTech solutions In case the resource is not 32 internally available, recruiting such professionals can pose a challenge for FIs, as there is currently high competition in both the private and public sectors for talent Furthermore, further training in the areas of management and supervision may be required for FI staff The chart below illustrates and summarizes some of the differences and operational challenges encountered in each RegTech segment However, the specific analysis of the challenges faced by FIs can be somewhat limited Figure 14: Obstacles and operational challenges per RegTech segment Nguồn: EBA For AML/CFT RegTech segment, the survey results exhibit that ‗Data and data quality Issues‘ (94%), ‗Integrating with legacy systems‘ (87%) and ‗Lack of data integration‘ (87%) are the most relevant obstacles, these being representative of the general obstacles perceived by FIs across all RegTech segments 33 For fraud prevention, FIs observe ‗Data and data quality Issues‘ (94%), ‗Cybersecurity threats‘ (87%) and ‗Integrating with legacy systems‘ (87%) as the most relevant issues, which illustrate that fraud prevention solutions contain cybersecurity threats aspects that need to be addressed For prudential reporting, the survey responses appear to be aligned with the findings related to the general obstacles FIs observe ‗Data and data quality issues‘ (89%), ‗Changes of national and international regulation‘ (89%) and ‗Integrating with legacy systems‘ (89%) as the most relevant issues for wider market adoption For ICT security RegTech solutions, the most relevant obstacles perceived by the FIs are ‗Data privacy and protection‘ (100%), ‗Security issues‘ (90%) and ‗Cybersecurity threats‘ (89%) which is in line with the general expectation that ICT security RegTech providers need to very carefully manage and address any (cyber)security‐related issues before the deployment of their solution within FIs‘ systems For CWA, the most widely considered obstacles are related to ‗Data and data quality issues‘ (100%), ‗Data privacy and protection‘ (100%) and ‗Lack of data integration‘ (100%) which suggests that RegTech providers need to address the issues related to processing of personally identifiable information Handling customer data puts the provider at risk in the event of cyberattacks and data leaks Cybersecurity concerns are greater among younger vendors, but grow with the amount of funding a company has raised Particularly exposed are vendors in the Dynamic Compliance segment of the market, whose capabilities for deeper integration with customer systems make them more likely targets for attacks of public network Unsurprisingly, companies in the Profiles and Due diligence segments are most concerned with privacy and data protection risks, while those that primarily process aggregated data but less interested 34 3.2 Solutions for RegTech technology development in the banking in Viet Nam In Vietnam, RegTech is not really popular yet, but it has been deployed many times in many different forms, through the application of digital transformation in activities for management, monitoring and compliance on the financial sector However, in order for RegTech to really develop in a proper, logical, systematic manner, the Fintech and Digital Banking reports issued by MB Bank have given recommendations to banks and Fintech companies and regulatory and supervisory agencies need to have a connection and this also requires a serious and methodical implementation Accordingly, RegTech needs to be properly and fully identified, avoiding identification with digital transformation during monitoring and management The most serious consideration of the effectiveness, applicability as well as difficulties when using RegTech will help the participants have a more appropriate implementation plan In addition, the application of RegTech needs to be deployed immediately in the experimental areas with utility applications that are best suited to Vietnamese conditions such as big data management (Big data), utilities for inspection reports, combined with financial crime prevention and control This also requires an appropriate and commensurate investment of resources because technology is the best lever for Vietnam to be able to keep up with major financial markets in the world Policymakers and supervisors need to reposition their roles as creators of a new, stronger and more sustainable financial industry, in an environment of incentives creativity, thereby helping the implementation of policy goals will be more convenient Firstly: to create a full legal framework and in the direction of creating favorable conditions for the development and application of fintech in financial-banking activities ✓ For Government: It is necessary to continue to improve the legal basis for the operation of these companies Issues related to researching the legal framework, completing the ecosystem and proposing methods of managing the RegTech sector in Vietnam need to ensure the 35 principles of consistency, efficiency and high consensus Accordingly, the assignment of a focal point to conduct research on specific Fintech contents should be assigned through a unified advisory focal point for the steering committee, which is the standing body of the steering committee In addition, the standing body is also the focal point to receive comments from members of the Vietnam RegTech community and coordinate with the International Cooperation Department of the SBV and the Ministry of Finance on cooperation activities RegTech in the context that RegTech activities in Vietnam are integrating with the region and the world Supplement regulations on new payment facilities, services, payment intermediary services, electronic money on the basis of applying international best practices and standards for a number of vehicles and systems payment system ✓ For the State Bank and the Ministry of Finance: The State Bank of Vietnam plays an important role in the development of the RegTech sector in Vietnam, especially in building a RegTech ecosystem based on Vietnam's advantages in terms of population size and human resources who are passionate about technology Given the indispensable role of RegTech in the financial banking sector in the current context of strong development of information technology, the SBV needs to promote its catalytic role to create a favorable legal foundation for its operations RegTech in Vietnam, towards a "level playing field" in the future for RegTech enterprises and commercial banks In the immediate future, during the testing phase, it is necessary to have clear regulations on the field, scope of activities, products and services, testing levels, procedures for registration of reports, testing and monitoring, and product announcements successful products and services and the ability to replicate At the same time, amend and supplement regulations on banking industry operations to be compatible and suitable with the context of "digitization" and the development of RegTech Thereby, encouraging cooperation and competition for mutual benefits between these two entities In particular, a number of key issues of RegTech need to focus on in order to have appropriate management policies as soon as possible, including: Blockchain technology and its application in the field of finance - banking, mobilization 36 and peer-to-peer lending, application program interface PI, electronic customer identification (e-ID) system for customer identification Second: Strengthening information safety and security measures Financial system - banks need to pay more attention to ensure the safety and privacy of customers' information systems and have new defense measures to keep information secure Accordingly, financial institutions and banks need to equip themselves with new security tools, pay more attention to building backup databases, upgrade security systems, and raise awareness on security, ensuring information safety throughout the system Promote communication of new dangers and threats through online sharing to prevent and minimize losses for stakeholders Deploying infrastructure services for information security: deploying industry clouds at the infrastructure and public cloud levels, ensuring efficiency and comprehensive information security Building an integrated platform for sharing service data, ensuring smoothness and cohesion between systems inside and outside the industry connecting network security operations centers, providing information on information security events and incidents to serve the management, supervision and operation of information security assurance for the whole industry The SBV and the National Financial Supervisory Commission need to renew the inspection and supervision of financial and banking activities in the direction of increasing the application of smart monitoring technologies and building an online warning system , and at the same time supervise payment activities according to modern international standards To step up the application of technology in the fight to prevent, stop and handle illegal acts in the financial - banking sector, especially for payment methods applying high technology At the same time, actively coordinate with technology companies and use appropriate financial resources to invest in security technologies to ensure network security such as: Technology to detect and patch technical vulnerabilities techniques, firewalls to prevent hackers' ability to attack 37 ● Commercial banks need to understand the new factors in operational risk when implementing cooperation with fintech enterprises, additional functions to solve risks to ensure security in banking operations ● Each organization and unit needs to focus on developing good data centers and enterprise networks to actively store information and prevent bad cases when a network attack occurs Third: Improve the quality of human resources in the financial - banking industry ● There should be close coordination between schools, training institutions and employers Related units need to connect, place orders to share information and be responsible for providing high-quality human resources to meet the requirements of the new technology era Universities and training institutions with majors related to finance and banking need to focus on intensive training in digital banking, e-commere, and information technology management to equip them with knowledge necessary for future human resources to catch up with modern banking technology trends Leading agencies such as the Ministry of Finance, the State Bank of Vietnam, the National Financial Supervisory Commission, the State Treasury need to continue to innovate and strengthen training and human resource development in the next direction approach the qualifications and standards of modern economies, in order to build a workforce with sufficient qualifications, professional capacity and ability to apply high technology At the same time, strengthen the training and fostering of information technology staff at credit institutions and financial institutions, in order to improve their professional qualifications and professionalism, to meet the needs of customers operation and mastery of modern technology systems In addition, it is necessary to strengthen domestic and international training linkages, and at the same time have a satisfactory remuneration regime for experts to encourage learning, fostering and improving qualifications, and attract talents work and contribute to the operation of the industry 38 3.3 Conclusion Regtech operates in many different areas of the financial and regulatory space Some of the regtech automation projects include employee monitoring, compliance data management, fraud prevention, and audit tracking capabilities The purpose of the article is to continue the discussion and debate about the evolution of the RegTech field and to provide a way of assessing ongoing progress It will allow both the public and private sectors to consider the capabilities needed to achieve trust in the digital age In Vietnam, RegTech needs to be deployed right in the test areas with utility applications that are best suited to Vietnamese conditions such as big data management (Big data), utilities for inspection reports, combined with financial crime prevention and control This also requires appropriate and commensurate investment of resources because technology is the best lever for Vietnam to keep up with major financial markets in the world Regtech is not really popular yet, but it has been deployed many times in many different forms, through the application of digital transformation in activities for management, monitoring and compliance on the financial sector Therefore, a balanced approach is needed to acknowledge the benefits of RegTech and create an environment that supports innovation, but at the same time close supervision and a willingness to manage any associated risks Chapter Summary We recognize a desire to improve the agenda from both regulators and companies, but this is only part of the story Addressing these barriers will take time, effort and a shift in industry confidence, but as regulation continues to evolve and we become a more global economy with more accessibility with financial products, our regulatory processes will have to change Companies and regulators can only this in cooperation with others - their local or national governments, universities and the private sector With 39 leadership, FIs can harness the wealth and positive enthusiasm for RegTech to provide a safer financial sector for all Financial Services has invested in technology to address key pressures, however, there is increasingly a business reason to address some of the deeper issues around regulation, to deal with systems and legacy processes are holding back real transformation Regtech has been helping Financial Services companies deliver and derive value from digital transformation, while maintaining the level of trust consumers are looking for The value in RegTech and its potential to generate significant benefits in the regulatory landscape of tomorrow Financial institutions like Start-ups, technology partners, Financial Services companies and regulators, so we can work together to support the broader public good, reducing losses harming consumers and creating confidence in Financial Service REFERENCES Authority, European banking (2021) EBA analysis of RegTech in the EU financial sector France Buckley, D W (2017) FinTech and RegTech in a 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CHAPTER : THE REGTECH TECHNOLOGY DEVELOPMENT IN THE BANKING AND FINANCE SECTOR .16 2.1 Effect of RegTech in the banking and finance sector: 16 2.1.1 Current RegTech landscape in the EU:.. .THE STATE BANK OF VIETNAM BANKING UNIVERSITY OF HO CHI MINH CITY GRADUATION THESIS THE REGTECH TECHNOLOGY DEVELOPMENT IN THE BANKING AND FINANCE SECTOR IN VIETNAM Major: FINANCE – BANKING. .. THE BANKING AND FINANCE SECTOR 2.1 Effect of RegTech in the banking and finance sector: 2.1.1 Current RegTech landscape in the EU: Based on a sample of financial institutions (FIs) and RegTech