Danos Group
19 Dec

In response to the global financial crisis of 2008, The Basel Committee on Banking Supervision has been working with global regulators to create new guidelines that ensure the banking sector has stronger capital standards for market risk and is more resilient in the face of any future crises.

The new standards include a more defined boundary between banking and trading books, a ‘Standardized Approach’ to risk metrics and a trading desk-level model approval process for ‘Internal Model Approaches’.

Despite the FRTB’s good intentions, it has faced scepticism and criticism as banks have been working to implement and test the new methods ahead of the deadline of 31st December next year.

Is it worth the cost?


Some are struggling with the financial impact of FRTB where the costs involved in the complex implementation and maintenance are high and the capital requirements and new rules on managing trades could impact profitability.

There are reports of significant reductions in inter-bank trading and the number of banks with active trading books. Some suggest that the costs inflicted by FRTB are a result of panic and not relative to the scale of the issue, suggesting there are quicker and cheaper fixes.


The Bank of England has estimated at its most conservative figure, the financial crisis cost in excess of $20 trillion. The knock on, global effect is significantly higher. Some consider the cost of changes that protect against a global economic disaster to be completely insignificant and totally justified.

John Beckwith and Sanjay Sharma, authors of ‘The FRTB: Concepts, Implications and Implementation’, even believe that FRTB can be adopted at a ‘reasonable cost’. FRTB can be more cost effective than existing methods such as stress testing and operationally, a lot of the work required in the implementation would have needed to have been carried out anyway as technological development leans more on data integration and model alignment.

Has FRTB been rendered obsolete before it’s even begun?


The trading world, going into 2019 is much different to 2010 when FTRB was first discussed. Since then other regulatory models such as Basel 2.5, stress tests, VaR, IRC, leverage ratios, resolution planning and capital buffers have significantly reduced risk. Value at Risks (VaRs) are now only a third of what they were back in 2007.


Beckwith and Sharma strongly believe that FRTB plays a critical role in the future protection of our financial services, correcting areas that are currently left exposed.

While they appreciate that regulation brought in since the financial crisis has made important steps forward, they don’t address the vulnerabilities that allowed it to happen in the first place. They say that weaknesses in market risk frameworks have been identified but not addressed which leaves ‘global markets and banking systems…prone to systemic shocks.’

FRTB goes beyond existing new capital calculations and is designed to, ‘transform the measurement and management of trading activities into robust processes that are sensitive to the observability and suitability of risk-factor sensitivities as they change over time’.

Addressing capital requirements is not enough when existing rules are open to manipulation by creative traders. Illiquid securities were ultimately responsible for the financial crisis and FRTB allows banks to attribute additional capital to risk factors as liquidity in trading assets decline.

Banks currently testing Internal Model Approaches (IMA) are experiencing failure rates of up to 79% when reconciling forecasted and actual losses, which shows that there is a need for tighter controls.

Some question that with so much focus on past activity, how adept FRTB will be at protecting the future but an under-recognised benefit of FRTB is that it is the market forces that drive the trading parameters, not the subsequent regulation after an incident has occurred.  The new framework captures emerging threats in specific risk factors and securities in real-time.

Are banks going to meet the deadline next year?


FRTB has been on the table since 2012 and banks appear to have been making good progress with their impact assessments and initial implementation this year.  They have the whole of 2019 to test the new risk models and are steadily working towards meeting the deadline at the end of next year as required.


While banks within the European Union are further ahead, many experts believe that full implementation of FRTB won’t be in place until 2025. In December 2016 the draft European legislation published by the EU in relation to FRTB said that the proposed amendments would start in 2019 ‘at the earliest’, that the date of application would be two years from 2019 and further still there would then be a three year phase-in period.

FRTB brings with it huge operational challenges. One of these is the requirement to source and calibrate 10 years of market data. Risk and finance have typically been separate functions and where the former looks at the future and the latter the past, it could take some time to bring the two together.

Will America ever actually adopt FRTB?


David Lynch, Deputy Associate Director with the Fed has been very clear that the US are going to implement FRTB. While admitting that the original version caused capital concerns, he is confident that their data quality and testing is now more on track.

He has said that the Basel Committee will complete its consultation and finalise rules this year, allowing enough time for feedback and adoption to meet the delayed implementation date of 2022.


Shortly after President Trump was elected, he issued an executive order for the US Department of the Treasury to review the American financial regulatory system. The Vice Chairman of the Financial Services Committee in the US House of Representatives had issued warnings on international rules and Congressman Patrick McHenry said that agreements like the Basel III accord ‘unfairly penalised the American financial system’ and that increases in capital requirements had led to slower growth in America.

Following this, a report issued in June 2017 advised US regulators to hold off on FRTB while it was investigated further. Later in December, the Basel committee on Banking Supervision decided to postpone international implementation until 2022. The enquiries and delays have caused people to question the US’s commitment to FRTB which has led some banks to take their attention away from it.

To conclude

We have seen an interesting mix in views. The drive to secure a more resilient banking sector has to be supported but those at the helm are raising important questions. Whatever your view, FRTB is going to be an important part of 2019 and Hiring Managers are building their teams accordingly. If you need support in hiring people with the right skills and experience for this task, please get in touch.

13 Dec

In the 14 years we have been specialising in the compliance sector, we have seen many trends and we’re witnessing a very interesting one now; financial crime in 2018 is mirroring the growth we saw in compliance between 2001 and 2016.

The highly aggressive global regulation on financial crime is driving demand, creating the same impact 9/11 and the credit crunch had on compliance. High profile anti-money laundering (AML) investigations are hitting the headlines on a regular basis, with reports of Deutsche Bank, Danske Bank and UBS all facing huge fines in the last few months.

With such significant scrutiny, financial crime has seen sustained growth in terms of: team numbers, compensation, department sizes, volumes of Managing Directors and therefore budgets allocated to servicing this function. This is exactly what we saw at the start of the rapid acceleration in compliance fifteen years ago.

The drive to protect against ever evolving threats requires talented, dedicated teams and the subsequent demand is pushing up compensation. For a sector that has previously had smaller budgets and less resource, we predict that by the end of 2019, the number of Managing Directors in financial crime and the level of compensation will be on a par with those in compliance at large international banking groups.

Compliance isn’t going anywhere, it still has its own constant supply of regulation to address but it is certainly evolving. The forecast for 2019 shows that it is critical for firms to have a solid financial crime operation and we’re very well placed to help with this. If you’d like to discuss strengthening your function, please get in touch.


28 Nov





John Fullick has joined Royal Bank of Canada as EME Head of Markets Compliance and Global Head of FX Compliance.

Mirka Gastaldello has joined Banco Santander as Head of Compliance and Financial Crime.

Philippe Vollot, has joined Danske Bank as their Chief Compliance Officer and is sitting on the board.

Andrew Garnett has joined Royal London Asset Management as Head of First Line Compliance.

Brett Hames has joined Exiger as Managing Director in the London office.

Natalie Bayliss has left GAM after only 3 months in her role as Chief Compliance Officer.

Don Scott had joined TCC Group to lead their Asset Management Practice.

Natasha Meaney has moved internally at UBS and is now the Global Head of Financial Crime.

Sara Cunningham has joined Polygon Global Partners as Head of European Regulatory and Compliance.

Marco Zwick has joined the Luxembourg regulator, CSSF as Director.

Stephan Wilken has moved internally at Deutsche Bank to become Head of Financial Crime and Group Anti-Money Laundering Officer.

Tim Minall joined PayPal in August 2018 as CRO EMEA with responsibility for Risk and Compliance EMEA.




Dale Nolan has left Goldman Sachs where he was EMEA CRO for the Securities Division. Dale has joined Intercontinental Exchange as CRO, ICE Clear Europe.

John Elder has left Credit Suisse where he was EMEA Head of Market Risk Methodology to join BlueCrest Capital.

Jeremy Arnold has left Nomura to join Natwest Capital Markets as CRO replacing Martyn Brush who left at the start of the year. RBS has also hired a new group CRO, Bruce Fletcher to replace David Stephen who has moved to become CRO at Westpac.


Legal – In-House


Corporate / Investment Banking:

Greg McEneny – General Counsel at Lloyds Corporate Bank. Greg was promoted from his position as a Deputy General Counsel for the Commercial Banking arm.

Edward Bibko – Acting General Counsel for EMEA and Asia, at Jefferies Investment Bank. Edward was previously The Head of Capital Markets at Baker and Mckenzie.

Claire Montgomery – European General Counsel at Credit Suisse. Claire was previously at Jefferies Investment Bank where she was General Counsel.

John Farry – Co-General Counsel, Corporate Investment Banking at Deutsche Bank. John was promoted from his position as the Global Head of CF/GCM and Global Transaction Banking.

Susan Revel – Deputy Chair and General Counsel EMEA at BNY Mellon. Susan has maintained her position to General Counsel and has been newly appointed as Deputy Chair of EMEA.

Amelia Gibbons – Former MD, Head of Global Finance Group EMEA, Credit Suisse AG. Amelia has recently left Credit Suisse although her recent post is unknown.

Steven Bartlett – General Counsel, Citi. Steven has been promoted from his previous MD position at Citi.

Jonathan Asher – Head of Global Markets Legal at Citi. Jonathan was promoted from his position as Head of Equity Derivatives Legal.

David Reynolds – Head of Global Markets London Legal and Global Coordinator for FICC, Legal, BNP Paribas. David has recently been promoted from Head of Derivatives Legal into this position.

Investment / Wealth Management:

Lodewijk van Setten – Former Chief Operating Officer, previously General Counsel of Morgan Stanley Investment Management joins KPMG as a Senior Brexit Adviser.

Phil Coffer – General Counsel, Aviva Investors. Phil has recently been promoted to the position of General Counsel.

Margo Jensen, SVP, Head of EMEA Legal – State Street Global Advisors. Margo has been promoted from MD to SVP at State Street.

Parisha Kanani – Group General Counsel, Company Secretary and Head of Company Secretariat at Octopus Investments. Parisha joins from First State Investments.

Rachel Wheeler – Group General Counsel at GAM (Zurich). Rachel joins from Aviva Investors in London.

Oliver Heiland – European Head of Alternatives Investments Legal (Frankfurt) at Allianz Global Investors EMEA. Oliver has recently been promoted from his position as Director Legal and Compliance.


Ehsan Haque, General Counsel at LendingBlock. Former Head of Equities Legal at Nomura joins blockchain technology based FinTech, Lendingblock.

Leigh Murrin – Head of Legal EMEA at Paypal (Luxembourg). Leigh joins Paypal from GE Capital where she was the Chief Legal Operations Counsel.


Legal – Private Practice


White & Case have been hiring extensively across multiple practice areas with the additions of private equity partner Emmie Jones from Macfarlanes, disputes partners David Robertson from BCLP, Steven Baker from Cadwalader as well as capital markets partner Gilles Teerlinck from Kirkland & Ellis.

Mayer Brown have boosted their Litigation & Dispute Resolution practice with the hires of partners Sam Eastwood and Jason Hungerford, both specialising in white collar, investigations and sanctions.

Latham & Watkins has expanded their restructuring capability with Sidley Austin restructuring duo Yen Sum and Jennifer Brennan as well as adding two more magic circle partners to the London office with the hire of infrastructure partner Conrad Andersen from A&O and infrastructure M&A head Brendan Moylan from Clifford Chance.

Taylor Wessing have grown their construction disputes team with the hire of partner Jonathan Hutt from RPC.

Vinson & Elkins have hired capital markets partner Noel Hughes from Sidley Austin. He will sit in the leveraged finance team focused on international capital markets and cross-border leveraged finance. In addition, Sidley Austin have also recently lost Matthew Dening, former managing partner of London and co-head of the global finance team, to Baker McKenzie where he was previously.

Fried Frank have hired Ashar Qureshi from Freshfields to head up its EMEA transactions practice.

Ashurst have enticed back derivatives partner Christopher Georgiou from Fieldfisher who was hired to lead its alternative legal services arm Condor.

Baker Botts has brought in David Ramm a corporate partner from Morgan Lewis & Bockius, not long after corporate partners, Mark Geday, Nicholas Moore and Tomasz Wozniak joined Morgan Lewis from Herbert Smith Freehills.

Sullivan & Cromwell have made a rare lateral hire with M&A partner Jeremy Kutner from Shearman & Sterling where he headed the TMT group.

MoFo have recruited Bonoit Lavigne from Ropes & Gray into its leveraged finance team. Benoit is the latest partner to leave the firm after a string of partner exits this year across multiple practice areas.




Jeff Horowitz joined Coinbase as Chief Compliance Officer.  Jeff was previously Chief Compliance Officer for Pershing LLP.

Howard Plotkin, US Chief Compliance Officer at Royal Bank of Canada has left the firm, a search is underway for his replacement.

JD (John) DiThomas has joined Boston-based crypto finance firm Circle as Lead Compliance Manager for payments.  DiThomas previously was a Compliance Director for Santander US for two years.

Alan Halfenger has joined Optima Partners Regulatory Consulting in New York as a Consulting Partner.  He was previously a Partner at ACA Compliance Group.

Angus Hamilton joins Liberty Lending as CCO from Petal (Credit Card).

Leonardo Real joins Tether, BVI blockchain start-up as Chief Compliance Officer.  Real previously was an AML Quality Control Manager for Bank of Montreal.




Andrew Chey has joined Rabobank in Hong Kong as APAC Head of Compliance.

BNP Paribas has a new APAC Head of Markets Compliance, based in Hong Kong.

Citi has a new APAC Head of Equities Compliance, they replace someone who has taken the same role with UBS, both in Hong Kong.

Angelina Kwan, ex Head of Compliance for Hong Kong Exchange & Clearing has joined Bitmex as COO, based in Hong Kong.

In Singapore Wee Soon Tan has joined DBS in their Financial Crime and Security Services team and Beaver Chua joined OCBC as Head of Group Policy Governance, AML and CFT.

27 Nov

Fintech is an important and growing sector in financial services across the globe. Earlier this month saw the return of the Singapore Fintech Festival and our Head of Singapore Adnan Maddix was in attendance, taking note of the challenges facing the sector in the months ahead.

Data Governance, Cloud Services and Cyber Security were said to be the three main focal points of the new age with buzzwords such as AI, The Cloud, Blockchain, APIs, data and advanced analytics becoming more commonplace across financial services.

Security is an important factor in the consumer’s decision-making process and banks are under pressure to offer rapidly developing, competitive products and services profitably while complying with regulation and protecting against cyber and financial crime. Unlike traditional banks, many areas of fintech are beyond regulation and they have to establish their own parameters in which to work.

Data Governance

A lot of emphasis is going to be put on businesses to make sure their customer data is protected against fraud. Matthew Chung, Managing Director and the Global Head of Technology and Information Risk at Morgan Stanley talked about the importance of earning trust. Firms have a responsibility to inform their consumers where their data is held and how it is protected, making sure they have full confidence in the steps taken.

Cyber Security

We, like Loren Bushkar, Managing Director in Global Membership for the Institute of International Finance (IIF) have seen a shift in Risk Analyst’s focus away from regulation to cyber security. While they have access to useful technology and frameworks so do the cyber criminals. John Nai, Chief Information Security Officer for PayPal said that because of this their period of effectiveness has gone from years to days, even hours and that security was an “arms race”.

Practices such as: simplifying the cyber infrastructure to improve “repeatability and recoverability”, getting basics such as staff training right, having excellent change management execution, good system checks, sharing information within the industry and having board-level buy-in were all ‘human’ elements cited as being able to aid the fight against cyber-attacks.

Artificial Intelligence (AI) is playing a growing role and fintech firms have the upper hand in understanding how technology can address issues and get the solutions in place quickly. Banks will benefit from partnering with fintech companies in the fight to be more technologically advanced and equipped than the attackers. One silver lining to come from the increasing and varying attacks is that with each one, comes an opportunity to gain intelligence and use that to help develop defenses.

Jennifer Calvery, Global Head, Financial Crime Threat Mitigation at HSBC highlighted the importance of using financial data in the fight against cyber-crime. She talked about their Intelligence-led solution which combines data analysis with artificial intelligence to generate data points. Analysing these, alongside support from the regulators has allowed them to build meaningful insights that could be shared with financial crime law enforcement.


Increasingly, traditional banking is seeking fintech innovation to remain competitive in the modern day. This drive for continuous improvement is promoting high performing services within the industry and security must be at the heart of it.

There are calls for regulators to adapt more quickly to the change and collaborate with other regulators to ease the complexity of international firms working across multiple jurisdictions. Richard Teng, CEO of the Financial Services Regulatory Authority, Abu Dhabi Global Market said that regulators must act as an ‘ecosystem developer’.

The Global Financial Innovation Network (GFIN) supports coordination of regulators and therefore innovation across borders. They talked about global sandboxes creating a structured platform for participants to collaborate with global regulators.


People are key to this change and development.

There was discussion about the difficulty of hiring and retaining talent and Cheng Li, CTO and COO of Ant Financial said that companies need to develop global partnerships but leverage local talent to succeed.

Myles Hosford, Head of Security & Compliance for APAC, Amazon Web Services also highlighted the role of recruitment saying that it was important to engage governance teams early in technological development to establish what requirements there are and to what extent they need to re-skill or hire.

As a head-hunter specialising in the governance area we work hard to identify and build relationships with the most talented candidates in the field. For anyone worried that the risk, compliance and financial crime market is slowing down, that simply isn’t correct. The landscape is changing, and our candidates are developing and adapting with it.

It is clear to see that many firms face changes in this area. If you would like our support, we can work with you to understand what you need and utilise our extensive network to match the best candidate to the role and the style of the organisation.

15 Nov




Brexit planning continues at pace with a number of UK headquartered firms retaining Danos Associates to find them compliance and financial crime talent across Europe.  In the last 6 months we have recruited in Dublin, Frankfurt, Luxembourg, Brussels, Amsterdam, Paris.

The London Market remains very busy with most firms actively recruiting new and replacement hiring. The London Compliance Private Equity sector has seen lots of activity with numerous senior appointments being made and the alternatives market as a whole in 2018 has been extremely buoyant with top firms attracting talent from Investment Banking especially. Consultancies continue to build bench strength for upcoming regulatory projects including SMCR.

Notable hiring is occurring within compliance across the fintech sector including cryptocurrency. Three senior financial crime appointments have been made in recent months continuing the trend of significant investment into financial crime controls at the large banking groups. UBS, Credit Suisse and Deutsche Bank have all made notable appointments.

The FCA has created a webpage on temporary authorisation to give firms more flexibility in not making final decisions until they know the UK situation. This has not stopped firms taking decisions and making changes. The FCA has also published a thematic review on money laundering and terrorist financing risk in the e-money sector and we have seen the sector start to review and make changes to their structures.


Electronic trading risk teams are being built out further at several leading investment banks both in London and New York. Quantitative research is in demand for both risk and the front office, especially candidates at AVP / VP level with x-asset experience.

Data science and machine learning (especially deep learning) expertise is also in demand across risk and the front office at banks, consultancies fintechs and buy-side firms creating significant competition with premiums for the better candidates. Fintech risk hiring is also active on the operational side and credit analysis. There has been a significant increase in roles in Frankfurt, Amsterdam, Luxembourg and Dublin.


Brexit overview

We found that there was a lot of activity in the legal job market at the start of 2018 in line with the trends extrapolated from 2017. As we approach the end of the year, we are observing a marginal decrease in permanent hires in contrast to consultant hires. There has been an increase in the need for senior consultants for various projects relating to contingency planning for when the UK exits the EU.

Since the beginning of summer 2018, we have seen an increase in demand for permanent senior hires across key financial hubs in Europe, particularly in Frankfurt, Dublin, Luxembourg and Paris. Demand outweighing the supply has caused competition for the best talent out there, increasing the need for financial services institutions to pay close to London market rates and benefits. We have also noticed increasing interest in London trained/based lawyers for roles in these financial hubs, supplementing the work force required in these cities.

These moves have been mirrored by the law firms – Simmons & Simmons is the third international firm to be launched in Dublin since the Brexit vote and Dentons have recently opened a fourth office in Dusseldorf to further fortify their presence in Germany.

In addition to the growth in continental Europe, the law firms in London have continued to see buoyant growth on the lateral hiring front. US law firms continue to dominate, with even those offices that rarely hire increasing headcount in strategic areas. It has been refreshing to hear positive news with regards to deal flow in the market with few partners stating any slowdown due to Brexit woes. Finance and dispute resolution hiring has been abundant as per previous, with steady M&A/PE growth and even some long-awaited movement within ECM. Interestingly, with the exception of a few high-profile team moves, the much anticipated surge in hiring within the restructuring area has been grossly under represented with few firms racing to expand.

Competitor information for 2018/2019 hiring plans

We anticipate that permanent legal hires in London will continue at the current pace through to the end of 2019. Most financial services institutions are gearing up for a surge in the number of consultant hires to enable them to fulfil the necessary requirements for the March 29 deadline and to deal with the post-Brexit transition. In relation to hiring in other European financial hubs, we expect an increase in permanent hires, inverse to the hiring plans of the same organisations in London at a similar time. Organisations are planning to hire senior lawyers into these offices first to deal with the immediate aftermath of Brexit, then steadily boost the number of lawyers over time.

In the private practice market, we expect to see the steady hiring of lateral partners continuing well in 2019. The general consensus being that firms will continue to ride the tide while it is high. However, with the area sensitive to market tremors, further signs of a ‘no deal Brexit’ as well as deep concerns regarding the global economy as a whole, may mean we see firms begin to aggressively bulk up their countercyclical offerings in order to hedge themselves against a market downturn.


The market in Hong Kong and Singapore remains busy despite heading towards year end. Whilst there has been growth in headcount in some buy-side firms as well as new entrants in fintech and regtech the majority of recent roles have been replacements.

With a steady stream of moves at all levels of seniority within compliance and financial crime, this musical chairs is set to continue into the New Year. Whilst some junior to mid-level moves are driven by salary increases and career progression, many of the more senior movements are a reflection of changes in direction and focus of both financial services firms and their compliance and regulatory approaches.


Financial crime has remained a growth area in the US, with many sell-side firms continuing in the general build-out across the space to upskill and increase capacity.  Others react to regulatory scrutiny and go out to the market with senior mandates to increase their capacity.

The quarter has seen a trend of hiring within regulatory relations across sell-side firms.  With there still being no common format for the function between peer firms across the industry, it remains a topic of conversation.  Most firms have been hiring within this space this summer.

The buy-side has seen notable movement at all levels with the usual migrations at more senior levels continuing, in addition to an interest in this side of the market from the mid – junior end of the market too.  With many buy-side firms building out more robust compliance functions, opportunities are being created at most levels.

08 Nov

We have talked a lot about the importance of diversity, so we were delighted to see so many of our clients in The Times Top 50 Employers for Women 2018.

This list highlights ‘the organisations that are transforming what it means to be a woman in the workplace’, celebrating their innovation in achieving gender equality.

The evaluation looks at areas such as; the roles of senior leaders, actions to increase representation of women in senior positions, recruitment, progression, supporting parents and economic empowerment of women in supply chains and communities.

These leaders have been; introducing returner and development programmes, supporting women into senior roles, encouraging girls in study, encouraging colleagues to write blogs about gender diversity in their workplace, challenging and changing practices, introducing networks and programmes dedicated to diversity and launching flexible working.

With so many of our clients being such high achievers in this space we need to make sure we as an organisation practice what we preach and have turned the spotlight on ourselves.

With the recent appointment of a female Head of Danos Consulting due to start in the new year, over 48% of our team are now women. 31% of those are in Global Management or Heads of Department positions, meaning four out of nine of our functions are led by women. A further 33% are either Associate Partners, Senior Associates or in management roles.  These figures put us in the same league as those in the Top 50 and like them it’s something we’re very conscious of building upon in our future strategy.

As a Father of three, our Global Managing Partner understands the importance of family life and we value the contribution of those who are able to work for us because of our flexible working allowances. This is an area that Barclays have been particularly strong. 57% of their workforce partake in flexible working and they have said that it has “empowered colleagues and been good for business.” We recognise that gender is just one element of building a high performing, diverse team. We are also very proud of our cultural diversity with extremely talented team members from lots of different ethnicities and walks of life.

The realisation that diversity impacts performance and the drive seen by companies to encourage change alongside the support given by regulation, makes now such a critical time for the future of our workplaces. If we support women in not only staying in work but rising to the top, the culture that will naturally arise from this greater balance will help engrain diversity as part of an organisations make up. Diversity will become more effortless – and we’ll be championing it all the way.

We are often asked to participate in diversity discussions and roundtables. If you would like our insight and support, please get in touch.