Voice-over: Welcome to Compliance Adviseerd. We talk with experts, advisors and business leaders about navigating risk and compliance challenges within the financial sector. Because the straight and narrow path doesn’t come with GPS. We’d like to thank our partners. Hyarchis, Deloitte , de Volksbank and Osborne Clarke. Your host is Jeroen Broekema.
Jeroen: Welcome listeners to a new episode of Leaders in Finance. Today in combination with the Compliance Advises podcast. Live from the Leaders in Finance Compliance event. And it’s literally 15 minutes ago that we got out of the event. And I’m here today with a couple of people that were speakers at the event. And with them, I’m going to reflect for about 20 minutes on this day. And obviously, if you want to know all about the event. You should definitely join us next year. But first of all, I’d like to introduce to you the four speakers I have with me today. These are Michelle Fisser who was the moderator of the day. Angelique Keijsers, she’s the Chief Compliance Officer at Unicredit. Angelique Meddeler, Chief Compliance Officer at Rabobank, and last but not least Christiaan Visser is a partner at Deloitte. This is just their names and their titles but I’d love to go around the table and learn a bit more about you guys. First of all Angelique Meddeler, Welcome.
Angelique Meddeler: Thank you, Jeroen. And well you already mentioned my name and my function. So I’ve been with Rabobank for about two and a half years in the Chief Compliance Officer’s role. Before that I spent over 25 years at ING. But always in the business. So for me, this is still fairly new. And therefore a day like this is extremely exciting to attend and to learn from my colleagues.
Jeroen: Great, great. And great you’re joining the podcast as well. Over to you Angelique Keijzer. We have two Angeliques, so I need to keep pronouncing your last names as well definitely. Could you please elaborate a bit on who you are.
Angelique Keijsers: Of course, of course. First of all it was a great day. I want to start with that. I really, really enjoyed it. And I am the Chief Compliance Officer of Unicredit GmbH, I have to make that more specific. We also have in Germany HypoVereinsbank. That’s how our bank is called in Germany. And I am there for three years right now. And before that I was within the Netherlands Chief Compliance Officer at Rabobank. And before that I’ve worked for other banks and for the consultancy. Since years already in the compliance arena, before that in audit. And what I said also in the consultancy environment. But always in the second, third line role. And yeah, it’s great to be here once more.
Jeroen: Wonderful. I mean just very, very small follow-up question. Because is it very different to work abroad now versus working in the Netherlands. I know you can probably talk about it for hours. But quick answer.
Angelique Keijsers: Yeah. And we did discuss that today during the event quite a lot. There are a lot of similarities of course. We have spoken about harmonization, about standardization. But also about the level playing fields within the different countries even in Europe. There are a lot of similarities. But also really some specific differences. Maybe one thing to highlight: the difference between rule-based and risk-based and the spirit of the law, the letter of the law. I think there are still some difference in the different countries.
Jeroen: Right. Thank you. And Michelle, welcome as well to the podcast. You were moderating the whole day. But maybe tell me a bit more about yourself.
Michelle: Thank you, Jeroen. Yeah, I’d like to echo the previous ladies. Because it was an amazing, amazing day and there’s a lot to talk about. Well, my name is Michelle Fisser. I have an experience in the field of compliance for more than 20 years, started in 2003. And also a number of years in consulting. After that, today I am the founder of Compliance in Motion. And the chairwoman of the Dutch compliance community.
Jeroen: Wonderful. Christiaan, over to you. Welcome as well to the podcast. And maybe you can do the same thing. And tell me a bit more about yourself.
Christiaan: Thank you, Jeroen. Indeed, partner at Deloitte. Where I have multiple roles. I lead the regulatory and compliance team. I’m also the lead client executive for two of the bigger banks in the Netherlands. And in addition to these functions, I’ve been active in the compliance world I think now for the majority of my life, So, more than 20 years. So, I’m a golden oldie as a banker but also as a compliance officer, and now in professional services.
Jeroen: We saw you on stage today. And you were moderating a panel. Where was the panel supposed to be about? And where was it ultimately about? Was it the same or was it different?
Christiaan: No, I think it was a great opportunity to connect with some chief compliance officers from the sector. Themost, I think, prestigious clients that we have in the Netherlands and in Europe. Yeah, we focused on some themes that we see in the market and it was very nice to see that those themes were not only relevant for the traditional banking sector but also for FinTech, and also even outside of the financial services sector. So, it was very recognizable. And it was really spot on, I believe.
Jeroen: And what was the theme you discussed with the chief compliance officers panel that you enjoyed the most? Or you found the most interesting?
Christiaan: Now, what I really liked was that the topic the importance of standardization in regulation but also in supervision is very important. I think for traditional financial services, but also within FinTech. To create a more level playing field and also improve effectiveness and efficiency in the market. So, it was really, really nice to see that it’s not only something that we see but also all other players in the ecosystem really recognize.
Jeroen: Angelique Meddeler, what was your takeaway of the panel? You were one of the speakers on that panel.
Angelique Meddeler: Yeah, I think there were many interesting topics discussed. And also between the panel members, I must say. So, I thought it was a lively discussion. A few takeaways I have is that the compliance function is still on a maturity journey. So, we’re not there. And compared to financial risk, it’s still maturing. One of the quotes of Rein Graat, CCO of ING, really resonated with me. That trust and credibility is not on the balance sheet but it’s maybe probably the most important assets of any corporation. So, I actually wrote that down. I’ll bring that home with me, that resonated a lot. And also the maturity, if I can call it that way, of the regulators. With all the new developments and also the links between them. I thought it was an interesting subject that we talked about.
Jeroen: Absolutely. Angelique Keijsers, you were on that panel as well. What was your takeaway? And what was the stuff you brought to the panel?
Angelique Keijsers: What we also discussed is how important technology and AI is, and data analysis and what have you. And as compliance officers, we are quite used to really look into details. But did it always in the old way, old-fashioned way. And we all strongly believe that because of all the regulations that are popping up and also the urgent requests that we sometimes have to reply to, that there is no way of not using better data quality but also conducting those analysis. And I think we were all quite sure that that’s relevant. But also highlighting it’s not always that easy. Because compliance and investing in new tools, etc. it’s of course not creating revenue but it’s important for all of us to ensure that our people, and our first line people business also understand how important it is to reply to all those requests. So, I think that was a lively discussion and I also believe that we all agreed how important this development is.
Jeroen: Right. And I think you guys also spoke about the fact that regulations are different in every country. And you need to deal with that, right? It’s not an easy one.
Angelique Keijsers: No, it’s absolutely not easy. And I think also Hanzo van Beusekom also replied to that. Also from the regulator’s point of view, you also see those challenges, ensuring that you have this level playing field. But also harmonization, what we also discussed during the panel. It sounds simple and it sounds easy. In practice, there are a lot of differences. I agree what we also discussed in the panel: it must be there, there must be a global approach. But in the execution and how to reply to all those requests, it’s not easy.
Angelique Meddeler: And if I can add to that, I thought the next panel with the FinTechs was actually quite interesting in that respect as well. Because actually this regulatory arbitrage, as it was called, also is actually a risk to the economy in itself. So, it’s nice to have very strict rules and regulations in terms of protecting. But if it has a detrimental effect on the economy and companies will not invest anymore in your country because of it, well, that’s also a risk in itself. So, I thought that was an interesting observation.
Jeroen: Interesting. This was a theme that came back both in your panel as well as in the FinTech. And then also again with Hanzo’s speech at the end of the day as representative of the regulator, the AFM, of course. Because he was pretty clear about the differences are still quite big. I mean, these are my words, but are quite big. Although in the FinTech panel, there were also people saying, well, there are minor differences, but they can have a big effect. So, I was a bit lost sometimes. So, what’s your take on it? Are the differences indeed so big or are they not that big?
Angelique Keijsers: A very concrete example was the inducements, the differences. And those are big. And those do have impact on revenue and on businesses. And that, I think, in the FinTech panel a discussion that popped up quite strongly. And this is a simple example, but a very big example. There’s a big difference between how the Dutch regulators perceive this topic and how in other countries this is being managed.
Jeroen: Yeah, this point was very strongly made by Tom Arends, the CEO of Peaks, right? Christine, you wanted to add something?
Christiaan: So, what I also liked about the discussion with Hanzo is that to move away a little bit from the differences is also important what your own preference is as a company. So, not only taking the view of legal, but also at harmful. And I think that is an important takeaway as well. We tend to focus really on regulation. And sometimes also get stuck in explanation of certain rules and do not take a position ourselves and I think that is an important thing to also take into account in your role as a compliance officer. That it’s also important to take a look at the harmful part and what kind of company do we actually want to be. A good takeaway, I believe, to prevent to get stuck in the firefighting mode.
Jeroen: Yeah, exactly. I think Hanzo also gave the example of crypto, which is now you could start to offer crypto as a bank, which is probably completely legal. But will it still be seen as legal or at least compliant in 10 or 15 years from now? I think it was Hanzo, if I’m not mistaken.
Michelle, you led the FinTech panel. What was one of your takeaways there? What was your thoughts on the panel?
Michelle: Besides echoing what Angelique and Angelique mentioned already. That’s funny. Sorry.
Jeroen: It’s the end of the day. That’s fine.
Michelle: It was interesting. It looked like sometimes the challenges were almost similar as the ones for the classic financial institutions. But sometimes it looked like the solution or the problem solving went quicker. And in our breakout session later, we discussed this again because I was talking to people working for FinTech, some for Peaks and some for another company. And they actually confirmed that because they say there are less layers. Maybe it’s sometimes easier to make a decision. At the end, it’s a FinTech. So the technology, you can just, you know, push the button and it may change while in a normal bank or it’s much more difficult. So I think that was one of the takeaways I had for today, which was an eye opener.
Jeroen: Angelique Meddeler?
Angelique Meddeler: Well, I think that also had to do with the tongue from the top. That’s what I heard Tom say. I as a CEO, at least that’s what I heard him say. I’m pushing this for everybody in my company to embrace wanting to be compliant as part of your normal job. And I guess if you start from a blank sheet of paper, right, if you can do that from the start, it’s easier. Whereas the other companies just have a lot of backlog to still work with. And I’m not so sure that everywhere in the business being compliant is embraced as part of your normal job. So that’s also something for compliance to help make that happen. But compliance cannot only make that happen, right?
Jeroen: And equally, you heard Emanuel van Praag, a professor at Erasmus, saying, well, my words, right, I’m not quoting anyone here, but something similar along the lines that there’s just no money to do certain things, right? If you’re very small. It’s not a question, but if you want to comment, please do. But otherwise, that was also, I mean, it’s, you know, maybe stating the obvious, but it is what happens, right? If you’re very small at a startup and you need to, as he said, you need to go to the next funding round, you need to get stuff done, it’s probably not the first thing you think about, but I don’t know. Other thoughts that stuck with you from this day. Is there something when you’re driving home tonight or for some biking home that you will think about or will remember? Is there something that comes to mind that really was either eye opening or just you thought it was a good idea to how it was brought to the audience?
Christiaan: Yeah, I really liked also from the speech from Hanzo that he mentioned how we’re all part of the same ecosystem. We’re actually playing at the same side of the fence and we’re not acting against each other, but we should reach out to each other across the three lines of defense. And even also the fourth line, the supervisor. I think that’s a really nice suggestion of Hanzo and also an open invitation to stay in contact with, for example, the AFM and D&B. And I think that was a great takeaway of today. It really felt inclusive among all attendees.
Angelique Keijsers: Yeah, I would like to reply to that because I think it is a very good message and I think we all want to do the same. The intention for all of us is to ensure that we have a good financial system. So transparency and reaching out to each other is important. And then if I then speak about the different regulators in the different countries, then I also experienced that positive approach also in Germany with BaFin and the Bundesbank. So I am a strong believer in transparency, open minded and sharing the challenges with each other. I think Hanzo also made very clear, but please do not come when the fire is already that big, but also share with us your challenges more in advance. And I think that is also a responsibility for all of us to ensure that we also approach the regulator in such kind of situations.
Angelique Meddeler: But it also made me realize again that the regulators do not make the law. So they are merely executing and as a consequence, they are part of the system. But we tend to forget that other people actually make the law that they then make us adhere to. So somehow we miss a party at the table to make sure that the full ecosystem can actually achieve what we want to achieve, which is a sound financial system.
Jeroen: I think it was one of his main points actually, right? He wasn’t that specific as you are now, but when he said, I feel your pain, quoting Bill Clinton, I think that’s what he meant. I mean, he started to list all the different regulations and laws coming. I mean, it’s an enormous amount, right? Who can ever oversee all of that, right? So I think they have also a hard time, they being a regulator, to deal with all of that, right? With only 700 people and there’s like, I don’t know, 200, 300 people working in financial service in the Netherlands.
Michelle: I also have one last one. We talked a lot about harmonization, but also about standardization. And especially, well, referring to the speech of Hanzo, for example, what of course we miss in the Netherlands is still a lot of guidance with respect to standardization. Because yes, harmonization can be difficult due to a lot of circumstances, especially internationally. But standardization, well, give everybody guidance. It starts already with the small things, right? Like how to do a risk assessment, how to write policies, how to build your frameworks. It’s better, easier, and if it is standardized, it’s also much easier to, at the end, monitor things or follow up from a supervisor.
Jeroen: There’s no one today in this short episode talking about Microsoft and ASML that were, you know, the outside perspective today. I find it very interesting as well. Anyone who want to comment on that? Because then we have covered all the different topics of the day.
Michelle: Shall I do it? Okay. Because what I found really nice and interesting, one of the questions was, of course, related to the drive to have a good compliance and ethics program in the organization. And I think that the responses of both André and Susan were very valuable for the audience, which showed that they were pretty successful in developing good programs, for example, for Speak Up or for other things they were doing. So, I think that was very valuable for today.
Jeroen: Great. Last question. Last two questions, basically, I have before we end this podcast. One is, is there something you found, you know, more on a, not as serious as the rest we’ve discussed today, but funny or you found something that stuck with you more on, you know, in that direction? That was my question before my last one. Anyone?
Angelique Keijsers: I want to highlight the way how AfM is looking at some challenges and the iceberg and the BEP and INA.
Jeroen: What were BEP and INA? Do you know the abbreviations?
Angelique Keijsers: Yeah, I think BEP is Begrepen and bekend.
Jeroen: Yes.
Angelique Keijsers: And INA ingewikkeld, nieuw and anders.
Jeroen: So, we need to translate that, right?
Angelique Keijsers: Yeah, you have to translate that.
Jeroen: So, bekend, right, known and understood.
Angelique Keijsers: Yeah.
Jeroen: The first one.
Angelique Keijsers: So, the given already.
Jeroen: INA is Complex, new and different.
Angelique Keijsers: Yeah. Yeah. And the way how they approach your day, it’s a little bit strange set, of course, but how they look at the different challenges and how to respond to observations, potential issues, potential incidents and how to deal with that, whether it’s already known or whether it’s completely new.
And I loved the, of course, the abbreviation of BEP and INA. I will not forget that. And I’m going to use it, by the way.
Jeroen: The Bep and Ina, and actually they’re discussed a lot in the board of the AFM, apparently. They use this term a lot.
Angelique Meddeler: Yeah. And I think in the end, the five insights were also actually at least very well known. So, and that somehow also gives a bit of comfort. So, there’s nothing new. It’s just mainly making sure that we do all these things right. That was for me also a takeaway.
Christiaan: Great. Yeah. Maybe a final one. So, I just mentioned that I’ve been working in compliance for 20 plus years, but also from the speech of Rein, I think it’s very nice to see that when I started at ING 20 plus years ago, we were nowhere near where ING is right now. As from a maturity perspective, aas Angelique Mettler just mentioned, we’re maturing as a function, but there’s already been a lot of maturing. So, we still got a way to go, but yeah, there’s also some real progress over the last couple of years.
Jeroen: Wonderful. Before I wrap this up, I’m very much looking forward to next year, the next edition. I will definitely call all of you up to ask what are the things we should be discussing next year. And before I’m going to thank you, is there something you want to leave us with a last final comment? This is the moment to do that.
Angelique Keijsers: I would like to make a last comment that I make quite often, but I think it’s important for all our colleagues, the compliance officers. Compliance is or should be a stepping stone for next steps in the business or in an organization. I strongly, strongly believe that having experience next to the first line, but in a second line function, whether it’s compliance risk or audit does give you a broader insight in all the challenges and risk appetite and what have you, what do you need to grow? I hope that this one, compliance being a stepping stone, is something that many companies are looking at and try to support that.
Jeroen: That’s a great one.
Angelique Meddeler: And next to that, and I fully agree with Angelique, it’s also, it’s about people. It’s not about rules and regulations. It’s about people and your own integrity and how you feel about things. And I think that sometimes fades a little bit away in this whole complexity of the regulatory landscape, but it’s really about people.
Jeroen: Extremely true. I believe so. Thank you.
Michelle: Yes. And of course, communication is key. Communication is key to share the message, but also to make sure that people well understood. That’s a bit of my end.
Christiaan: Boom. Very clear, Michelle. Thanks. I would like to reiterate the point that I made earlier. Let’s connect in an ecosystem. Very important. Let’s keep on connecting, having open conversations, and then we can only improve further.
Jeroen: I’m very much looking forward to have you here next year. I hope, Angelique Keijsers, that it’s not a stepping stone right away for one of you. So, next year, you’re not in compliance anymore and uou’re not showing up here. But if you’re in the business, you should come to compliance events from Leaders & Finance as well. So, Michelle Fisser, Angelique Keijsers, Angelique Meddele, and Christiaan Visser, thanks a lot for sharing your ideas and your reflections on this event today. I know it was very valuable time you spent with me here because other people are going to the drinks at the moment. And you guys are recording an episode for Leaders & Finance slash Compliance Adviseerd. So, thanks a lot for taking the time. And I’m very much looking forward to see you next year.
Voice-over: Thank you. Thank you. You’ve been listening to Compliance Adviseert, made with the help of Deloitte, De Volksbank, Hiarchis, and Osborne Clark. Would you like to know more or leave us a comment? You can do this on our LinkedIn page. If you follow us there, we’ll keep you up to date with our new episodes. We’d be grateful if you could leave a review and tell others about this podcast. Also, don’t forget to check out the other podcasts on our channel. There’s bound to be something for you.
