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Knowing your
customer is one thing.
Understanding
them is everything.
Continuous KYC from Accenture + Quantexa.
Introducing a new, dynamic risk assessment model.
An approach that combines solid knowledge of the
regulatory environment with cutting-edge tools to
give you an expanded view of your clients.
Copyright © 2020 Accenture. All rights reserved.
First established in rapid response
to new regulation, it’s hardly surprising
that the Know Your Customer (KYC)
function is seen as time-intensive,
laborious and frustrating. Customer
experience was never part of the
equation; the goal was to demonstrate
compliance at all costs.
But now we’re familiar with the
fundamentals, we can make KYC
so much more. The next step is bigger
than mastering efficiencies. It’s time
to integrate it with broader client
management strategies so that we can
greatly improve the KYC experience.
Turn compliance
into a customer
experience
opportunity
2
Copyright © 2020 Accenture. All rights reserved.
3
Copyright © 2020 Accenture. All rights reserved.
Rising Costs
Due to KYC and Customer Due
Diligence (CDD), compliance
spending is on the rise. 72%
of financial services firms are
targeting Compliance cost
reductions of >10% over the
next 3 years.* We also see
a loss of revenue, as lengthy
onboarding times drive
clients to go elsewhere.
Increasing Inefficiency
Ownership structures are
increasingly complex and
hide criminality, politically
exposed persons PEP and
sanctions connections.
The current model of periodic
reviews is resource intensive
and rarely results in a change
of risk rating.
Client Frustration
KYC checks can be repetitive
and often cause clients to
switch banks. Onboarding
is highly-manual, and with
limited automation and review
strategies, customers are
contacted multiple times
throughout. The result:
they vote with their feet.
The complexity of KYC has resulted in
skyrocketing costs, with little improvement
in effectiveness and client satisfaction.
*Data from the Accenture 2019 Compliance Risk Study
What needs to change?
Highly manual workload
No automated research
High manual collection process
Multiple hand-offs between
Ops / Risk Management (RM) / Client
High amount of false positives
The current situation
4
Copyright © 2020 Accenture. All rights reserved.
Handling times:
Retail / Domestic Small and medium-sized
enterprises (SME) / Corporates
Large Corporates
2–7 hours 7–18 hours 25–45 hours
 No integrated screening tools
 High manual investigation efforts
 Fragmented workflow
 Frequent changes to CDD standards
 Difficult to identify client
Ultimate Beneficial Owner (UBO)
5
Copyright © 2020 Accenture. All rights reserved.
The below diagram provides a high level overview of the current end to end
KYC process and highlights some of the key challenges faced by clients:
Current KYC reviews are manual and
based on a static periodic review cycle
Largely Manual Process
Adverse media
& name list screening
Collect info/docs
and assess gaps
DATA SOURCING
& MANAGEMENT
CASE
REVIEW
Distribute &
assign cases
Set-up KYC
record
Triggers
Onboarding
Periodic
CASE
GENERATION
Up to 20 iterations
Manual
construct
of
corporate
hierarchy
CUSTOMER NETWORK
BUILD & SCREENING
Acquisition of
external data
Manual google
search 30+ min.
Due diligence,
risk rating
and decision
OPS
RM
CLIENT
Re-work if data update
ENHANCED
DUE DILLIGENCE
Final
assessment
KYC/onboarding
decision
Business
acceptance
Acceptance / first time
pass rate < 50 %
Escalations
to compliance
OPS
RM
CLIENT
6
Copyright © 2020 Accenture. All rights reserved.
Continuous KYC
from Accenture
+ Quantexa
Introducing a new model
Accenture has partnered with Quantexa
to develop a dynamic client risk assessment
model for banks. Accenture’s knowledge
of the ever-changing regulatory environment,
combined with Quantexa’s contextual
decision intelligence platform, gives you
an ever-evolving view of your customer in
an approach we call Continuous KYC (cKYC).
7
Copyright © 2020 Accenture. All rights reserved.
Automated
Threat Monitoring
A shift from periodic
to event-based
reviews through
automated threat
monitoring. Low risk
changes are flagged
removing the need
for manual checks.
Dynamic
Risk Scoring
A renewed focus on
the behavioral and
transactional context
of clients. Constant,
dynamic risk scoring
that takes a data-driven
and risk-based approach
across all KYC and
CDD activities.
Unified
Network View
Link all related
entities into a single
dynamic network
of KYC profiles,
with automated
KYC data collection
and integration.
Simplified
Enhanced
Due Diligence
Monitor the entire
customer network
as generated and flag
any potential hidden
risk. Perform enhanced
due diligence based
on exceptions.
What does an evolving
view of your client look like?
8
Copyright © 2020 Accenture. All rights reserved.
*Data from Thomson Reuters 2016 Know Your Customer Survey,
https://www.thomsonreuters.com/en/press-releases/2016/may/
thomson-reuters-2016-know-your-customer-surveys.html
While financial firms’ average costs to meet
their obligations are $60 million according
to one survey, some are spending up to
$500 million on compliance with KYC and CDD.*
The costs and complexity of KYC are rising
and negatively impacting businesses.
cKYC lowers costs…
cKYC allows banks to
improve inefficiencies in
their KYC process through
automation, leading to a
significant reduction in
the cost of KYC.
Continuous KYC positively
impacts all elements of
the KYC process
cKYC elevates your business’ KYC function above
the current industry standard through improvements
in Case Generation, Data Sourcing, Screening,
Case Review and Enhanced Due Diligence.
cKYC future state
Case Generation
Data Sourcing and Management
Event-based model
Mostly manual
Mostly automated,
some manual
Manual data collation Automated data collation
Enhanced Due Diligence (EDD)
High number of
escalations
Simplified, exceptions
based escalations
Most cases require EDD Few cases require EDD
Case Review
Client contact
required in all cases
No client contact required
Most cases require
client contact
Few cases require
client contact
Customer Network Build and Screening
Screen at review
Customer / connected parties
generate their own alerts
Screened mostly periodically
Screened mostly through
portfolio monitoring
Time based cycle
Mostly periodic
Mostly event based,
some periodic
9
Copyright © 2020 Accenture. All rights reserved.
10
Copyright © 2020 Accenture. All rights reserved.
More tools,
better answers
When analytics,
search, data
visualization and
AI come together,
so too does a more
detailed portrait
of your clients.
More automation,
renewed trust
The client experience
is a happy one when
unnecessary back
and forth processes
are reduced.
More analytics,
stronger
connections
Bank managers
can build better
relationships with
clients when they
are able to draw the
right conclusions
from your data.
More data,
higher accuracy
Getting a precise
picture of your
clients is easy
when changes
in your data sets
are automatically
flagged.
And brings big benefits…
11
Copyright © 2020 Accenture. All rights reserved.
Accenture + Quantexa
Solving Industry
Problems
Co-creation of financial
crime capability
Strategic
Partnership
Accenture’s Financial Crime and Digital
group is able to bring a wealth of
experience in undertaking large scale
transformations in KYC, and is at the
forefront of industry transformation
at a number of clients.
Building on our experiences of process,
data and technology transformations, we
are able to bring the right skills, experience
and industry insight to drive significant
business outcomes for clients, leading to an
increase in operational efficiency, reduced
volumes and increased risk management.
12
Copyright © 2020 Accenture. All rights reserved.
Quantexa’s Contextual Decision Intelligence
(CDI) platform connects billions of data points
across internal and external data sources,
to provide a single contextual view enriched
with vital intelligence about the network of
relationships between people, organizations
and places.
Our Financial Crime and Risk monitoring solutions
provide the context needed to uncover hidden
risk more efficiently and with greater accuracy
than traditional systems, reducing false positives
by over 90% and empowering teams to focus on
real risk and make better operational decisions.
13
Copyright © 2020 Accenture. All rights reserved.
14
Copyright © 2020 Accenture. All rights reserved.
Final
Assessment
Escalations
to Compliance
Investigation
Identified
Risk
Customer
Outreach
Distribute and
Assign Cases
Set-up KYC
Record and
Pre-scoring
Review
Info/Docs and
Assess Gaps
Client Contact
and Screening
(Exceptions Only)
Due Diligence,
Risk Scoring and
Threat Detection
Automated
Client Contact
Screening
of Customer
Network
Onboarding
Request
Data
Collation
Entity
Resolution
Generate
Customer Record
and Network View
Data Attribute
Matching
Data
Standardization
Triggers
Onboarding
Periodic
AUTOMATED
PROCESS
REDUCED
MANUAL EFFORT
Reduced
Handling Times
Data & Customer
Context Driven
Improved Risk
Identification
Focused
Triggers
CASE
GENERATION
CASE
REVIEW
ENHANCED
DUE DILLIGENCE
CUSTOMER NETWORK
BUILD AND SCREENING
DATA SOURCING
AND MANAGEMENT
Our process
15
Copyright © 2020 Accenture. All rights reserved.
Automated Customer
Data Collation
Build a single 360 degree
view of the customer.
Automatically search
external and internal
data sources to identify
all information available
about the customer.
Entity Resolution,
and Network
Generation
Resolve the entity
on external sources,
identify any hidden
relationships and generate
improved accuracy
from screening results.
Automated
Client Contact
Outreach via
client‘s preferred
contact channel
and servicing
portals to collect
and update
information.
Advanced,
Accurate
Analytics
Advanced data
analytics to inform
risk scoring and
changes to known
client information
to accurately trigger
KYC reviews.
Improved
Triggers
Reduced trigger
volumes and only
focused on relevant
cases where customer
risk has changed.
More Effective
Case Review
Reduce manual processes.
The data collated before
a case is triggered is
presented, and reviews
no longer require
extensive data gathering
and multiple back and
forth with the client.
Effective
Enhanced
Due Diligence
We use risk scores
and network graphs
to simplify enhanced
due diligence and
identify financial
crime risks, escalating
them as needed.
Our solutions
16
Copyright © 2020 Accenture. All rights reserved.
Tailored Design
Every journey to cKYC is
unique, so we don’t roll
out a standard “off the shelf”
framework. We design our
solution around your policy,
preferred data sources
and overall strategy.
Self-sufficient
Technology
New tech shouldn’t clash
with the old. Our open
architecture tools can be
easily integrated with your
existing stack.
End-to-end
Transformation
Our approach covers the
entire compliance process,
including your people. We
provide upskilling in data
and analytics, change
management and risk
advisory services.
How we work with you
17
Copyright © 2020 Accenture. All rights reserved.
Phase 2: Tailored
Solution Design
Client specific solution designed
to gather required KYC information
from preferred data sources.
Quantexa solution connects
to client’s preferred internal
and external data sources.
Phase 3: Pilot
Deploy of Tailored Continuous
KYC solution to a pilot population.
Measure and quantify benefit of
deployment to pilot population.
Phase 4: Test
and Improve
Gather machine intelligence
(MI) data coverage metrics and
identify areas for improvement.
Introduce further data sources
to allow for iterative improvement
in accuracy of risk events, better
assessment of materiality,
and enhanced investigation.
Phase 5: Deploy to
entire KYC population
Connect to further data sources and
use other techniques like inference to
gather required KYC information for
other customer segments or countries.
Deploy tailored continuous KYC
solution design to wider population.
Phase 6: Continual
Risk Management
Investigations driven by a range
of ‘triggers’.
MI automates most decisions
with specialized human input
for key risks only.
Improved customer experience,
reduced workload and better
risk control.
Phase 1: Current
State Assessment
Understand client end-to-end
KYC process today.
Make sure client is able to
support capabilities required
to implement Continuous KYC.
The journey to cKYC
18
Copyright © 2020 Accenture. All rights reserved.
Ready to begin? Get in touch.
Andy Frost
Europe, the Middle East
and Africa, Quantexa
Mark McNerney
Global Alliances
Director, Quantexa
Derek Brown
Americas,
Quantexa
Shaun Mathieson
Asia Pacific,
Quantexa
Heather Adams
Managing Director,
Risk Resilience Lead,
United Kingdom & Ireland
Archit Chamaria
Senior Manager,
United Kingdom & Ireland
Sapan Dogra
Managing Director,
Applied Intelligence
Adam Markson
Managing Director,
Risk Lead, United Kingdom
& Ireland
19
Copyright © 2020 Accenture. All rights reserved.
Continuous KYC by Accenture + Quantexa
About Accenture
Accenture is a leading global professional services
company, providing a broad range of services in strategy
and consulting, interactive, technology and operations,
with digital capabilities across all of these services.
We combine unmatched experience and specialized
capabilities across more than 40 industries—powered
by the world’s largest network of Advanced Technology
and Intelligent Operations centers.
With 509,000 people serving clients in more than 120
countries, Accenture brings continuous innovation to help
clients improve their performance and create lasting value
across their enterprises. Visit us at www.accenture.com
Disclaimer
This presentation is intended for general
informational purposes only and does not
take into account the reader’s specific
circumstances, and may not reflect the
most current developments. Accenture
disclaims, to the fullest extent permitted
by applicable law, any and all liability for
the accuracy and completeness of the
information in this presentation and for
any acts or omissions made based on such
information. Accenture does not provide
legal, regulatory, audit, or tax advice.
Readers are responsible for obtaining
such advice from their own legal counsel
or other licensed professionals.

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Continuous KYC from Accenture + Quantexa

  • 1. Knowing your customer is one thing. Understanding them is everything. Continuous KYC from Accenture + Quantexa. Introducing a new, dynamic risk assessment model. An approach that combines solid knowledge of the regulatory environment with cutting-edge tools to give you an expanded view of your clients. Copyright © 2020 Accenture. All rights reserved.
  • 2. First established in rapid response to new regulation, it’s hardly surprising that the Know Your Customer (KYC) function is seen as time-intensive, laborious and frustrating. Customer experience was never part of the equation; the goal was to demonstrate compliance at all costs. But now we’re familiar with the fundamentals, we can make KYC so much more. The next step is bigger than mastering efficiencies. It’s time to integrate it with broader client management strategies so that we can greatly improve the KYC experience. Turn compliance into a customer experience opportunity 2 Copyright © 2020 Accenture. All rights reserved.
  • 3. 3 Copyright © 2020 Accenture. All rights reserved. Rising Costs Due to KYC and Customer Due Diligence (CDD), compliance spending is on the rise. 72% of financial services firms are targeting Compliance cost reductions of >10% over the next 3 years.* We also see a loss of revenue, as lengthy onboarding times drive clients to go elsewhere. Increasing Inefficiency Ownership structures are increasingly complex and hide criminality, politically exposed persons PEP and sanctions connections. The current model of periodic reviews is resource intensive and rarely results in a change of risk rating. Client Frustration KYC checks can be repetitive and often cause clients to switch banks. Onboarding is highly-manual, and with limited automation and review strategies, customers are contacted multiple times throughout. The result: they vote with their feet. The complexity of KYC has resulted in skyrocketing costs, with little improvement in effectiveness and client satisfaction. *Data from the Accenture 2019 Compliance Risk Study What needs to change?
  • 4. Highly manual workload No automated research High manual collection process Multiple hand-offs between Ops / Risk Management (RM) / Client High amount of false positives The current situation 4 Copyright © 2020 Accenture. All rights reserved. Handling times: Retail / Domestic Small and medium-sized enterprises (SME) / Corporates Large Corporates 2–7 hours 7–18 hours 25–45 hours  No integrated screening tools  High manual investigation efforts  Fragmented workflow  Frequent changes to CDD standards  Difficult to identify client Ultimate Beneficial Owner (UBO)
  • 5. 5 Copyright © 2020 Accenture. All rights reserved. The below diagram provides a high level overview of the current end to end KYC process and highlights some of the key challenges faced by clients: Current KYC reviews are manual and based on a static periodic review cycle Largely Manual Process Adverse media & name list screening Collect info/docs and assess gaps DATA SOURCING & MANAGEMENT CASE REVIEW Distribute & assign cases Set-up KYC record Triggers Onboarding Periodic CASE GENERATION Up to 20 iterations Manual construct of corporate hierarchy CUSTOMER NETWORK BUILD & SCREENING Acquisition of external data Manual google search 30+ min. Due diligence, risk rating and decision OPS RM CLIENT Re-work if data update ENHANCED DUE DILLIGENCE Final assessment KYC/onboarding decision Business acceptance Acceptance / first time pass rate < 50 % Escalations to compliance OPS RM CLIENT
  • 6. 6 Copyright © 2020 Accenture. All rights reserved. Continuous KYC from Accenture + Quantexa Introducing a new model Accenture has partnered with Quantexa to develop a dynamic client risk assessment model for banks. Accenture’s knowledge of the ever-changing regulatory environment, combined with Quantexa’s contextual decision intelligence platform, gives you an ever-evolving view of your customer in an approach we call Continuous KYC (cKYC).
  • 7. 7 Copyright © 2020 Accenture. All rights reserved. Automated Threat Monitoring A shift from periodic to event-based reviews through automated threat monitoring. Low risk changes are flagged removing the need for manual checks. Dynamic Risk Scoring A renewed focus on the behavioral and transactional context of clients. Constant, dynamic risk scoring that takes a data-driven and risk-based approach across all KYC and CDD activities. Unified Network View Link all related entities into a single dynamic network of KYC profiles, with automated KYC data collection and integration. Simplified Enhanced Due Diligence Monitor the entire customer network as generated and flag any potential hidden risk. Perform enhanced due diligence based on exceptions. What does an evolving view of your client look like?
  • 8. 8 Copyright © 2020 Accenture. All rights reserved. *Data from Thomson Reuters 2016 Know Your Customer Survey, https://www.thomsonreuters.com/en/press-releases/2016/may/ thomson-reuters-2016-know-your-customer-surveys.html While financial firms’ average costs to meet their obligations are $60 million according to one survey, some are spending up to $500 million on compliance with KYC and CDD.* The costs and complexity of KYC are rising and negatively impacting businesses. cKYC lowers costs… cKYC allows banks to improve inefficiencies in their KYC process through automation, leading to a significant reduction in the cost of KYC.
  • 9. Continuous KYC positively impacts all elements of the KYC process cKYC elevates your business’ KYC function above the current industry standard through improvements in Case Generation, Data Sourcing, Screening, Case Review and Enhanced Due Diligence. cKYC future state Case Generation Data Sourcing and Management Event-based model Mostly manual Mostly automated, some manual Manual data collation Automated data collation Enhanced Due Diligence (EDD) High number of escalations Simplified, exceptions based escalations Most cases require EDD Few cases require EDD Case Review Client contact required in all cases No client contact required Most cases require client contact Few cases require client contact Customer Network Build and Screening Screen at review Customer / connected parties generate their own alerts Screened mostly periodically Screened mostly through portfolio monitoring Time based cycle Mostly periodic Mostly event based, some periodic 9 Copyright © 2020 Accenture. All rights reserved.
  • 10. 10 Copyright © 2020 Accenture. All rights reserved. More tools, better answers When analytics, search, data visualization and AI come together, so too does a more detailed portrait of your clients. More automation, renewed trust The client experience is a happy one when unnecessary back and forth processes are reduced. More analytics, stronger connections Bank managers can build better relationships with clients when they are able to draw the right conclusions from your data. More data, higher accuracy Getting a precise picture of your clients is easy when changes in your data sets are automatically flagged. And brings big benefits…
  • 11. 11 Copyright © 2020 Accenture. All rights reserved. Accenture + Quantexa Solving Industry Problems Co-creation of financial crime capability Strategic Partnership
  • 12. Accenture’s Financial Crime and Digital group is able to bring a wealth of experience in undertaking large scale transformations in KYC, and is at the forefront of industry transformation at a number of clients. Building on our experiences of process, data and technology transformations, we are able to bring the right skills, experience and industry insight to drive significant business outcomes for clients, leading to an increase in operational efficiency, reduced volumes and increased risk management. 12 Copyright © 2020 Accenture. All rights reserved.
  • 13. Quantexa’s Contextual Decision Intelligence (CDI) platform connects billions of data points across internal and external data sources, to provide a single contextual view enriched with vital intelligence about the network of relationships between people, organizations and places. Our Financial Crime and Risk monitoring solutions provide the context needed to uncover hidden risk more efficiently and with greater accuracy than traditional systems, reducing false positives by over 90% and empowering teams to focus on real risk and make better operational decisions. 13 Copyright © 2020 Accenture. All rights reserved.
  • 14. 14 Copyright © 2020 Accenture. All rights reserved. Final Assessment Escalations to Compliance Investigation Identified Risk Customer Outreach Distribute and Assign Cases Set-up KYC Record and Pre-scoring Review Info/Docs and Assess Gaps Client Contact and Screening (Exceptions Only) Due Diligence, Risk Scoring and Threat Detection Automated Client Contact Screening of Customer Network Onboarding Request Data Collation Entity Resolution Generate Customer Record and Network View Data Attribute Matching Data Standardization Triggers Onboarding Periodic AUTOMATED PROCESS REDUCED MANUAL EFFORT Reduced Handling Times Data & Customer Context Driven Improved Risk Identification Focused Triggers CASE GENERATION CASE REVIEW ENHANCED DUE DILLIGENCE CUSTOMER NETWORK BUILD AND SCREENING DATA SOURCING AND MANAGEMENT Our process
  • 15. 15 Copyright © 2020 Accenture. All rights reserved. Automated Customer Data Collation Build a single 360 degree view of the customer. Automatically search external and internal data sources to identify all information available about the customer. Entity Resolution, and Network Generation Resolve the entity on external sources, identify any hidden relationships and generate improved accuracy from screening results. Automated Client Contact Outreach via client‘s preferred contact channel and servicing portals to collect and update information. Advanced, Accurate Analytics Advanced data analytics to inform risk scoring and changes to known client information to accurately trigger KYC reviews. Improved Triggers Reduced trigger volumes and only focused on relevant cases where customer risk has changed. More Effective Case Review Reduce manual processes. The data collated before a case is triggered is presented, and reviews no longer require extensive data gathering and multiple back and forth with the client. Effective Enhanced Due Diligence We use risk scores and network graphs to simplify enhanced due diligence and identify financial crime risks, escalating them as needed. Our solutions
  • 16. 16 Copyright © 2020 Accenture. All rights reserved. Tailored Design Every journey to cKYC is unique, so we don’t roll out a standard “off the shelf” framework. We design our solution around your policy, preferred data sources and overall strategy. Self-sufficient Technology New tech shouldn’t clash with the old. Our open architecture tools can be easily integrated with your existing stack. End-to-end Transformation Our approach covers the entire compliance process, including your people. We provide upskilling in data and analytics, change management and risk advisory services. How we work with you
  • 17. 17 Copyright © 2020 Accenture. All rights reserved. Phase 2: Tailored Solution Design Client specific solution designed to gather required KYC information from preferred data sources. Quantexa solution connects to client’s preferred internal and external data sources. Phase 3: Pilot Deploy of Tailored Continuous KYC solution to a pilot population. Measure and quantify benefit of deployment to pilot population. Phase 4: Test and Improve Gather machine intelligence (MI) data coverage metrics and identify areas for improvement. Introduce further data sources to allow for iterative improvement in accuracy of risk events, better assessment of materiality, and enhanced investigation. Phase 5: Deploy to entire KYC population Connect to further data sources and use other techniques like inference to gather required KYC information for other customer segments or countries. Deploy tailored continuous KYC solution design to wider population. Phase 6: Continual Risk Management Investigations driven by a range of ‘triggers’. MI automates most decisions with specialized human input for key risks only. Improved customer experience, reduced workload and better risk control. Phase 1: Current State Assessment Understand client end-to-end KYC process today. Make sure client is able to support capabilities required to implement Continuous KYC. The journey to cKYC
  • 18. 18 Copyright © 2020 Accenture. All rights reserved. Ready to begin? Get in touch. Andy Frost Europe, the Middle East and Africa, Quantexa Mark McNerney Global Alliances Director, Quantexa Derek Brown Americas, Quantexa Shaun Mathieson Asia Pacific, Quantexa Heather Adams Managing Director, Risk Resilience Lead, United Kingdom & Ireland Archit Chamaria Senior Manager, United Kingdom & Ireland Sapan Dogra Managing Director, Applied Intelligence Adam Markson Managing Director, Risk Lead, United Kingdom & Ireland
  • 19. 19 Copyright © 2020 Accenture. All rights reserved. Continuous KYC by Accenture + Quantexa About Accenture Accenture is a leading global professional services company, providing a broad range of services in strategy and consulting, interactive, technology and operations, with digital capabilities across all of these services. We combine unmatched experience and specialized capabilities across more than 40 industries—powered by the world’s largest network of Advanced Technology and Intelligent Operations centers. With 509,000 people serving clients in more than 120 countries, Accenture brings continuous innovation to help clients improve their performance and create lasting value across their enterprises. Visit us at www.accenture.com Disclaimer This presentation is intended for general informational purposes only and does not take into account the reader’s specific circumstances, and may not reflect the most current developments. Accenture disclaims, to the fullest extent permitted by applicable law, any and all liability for the accuracy and completeness of the information in this presentation and for any acts or omissions made based on such information. Accenture does not provide legal, regulatory, audit, or tax advice. Readers are responsible for obtaining such advice from their own legal counsel or other licensed professionals.