Anthony Cosgrove MBE

Unless you worked in the Government Digital Service in the 2010s, you've probably never head of GOV.UK Registers. The premise was very sensible: to create canonical lists of useful data that can be re-used across Government and industry. Why does this matter? Well, imagine if different Government departments kept different lists of the countries in the world. Imagine the gaffes that would be caused if one department recognised Taiwan as a country, and another did not. Or imagine that there were two completely independent teams in the Department for Health and the NHS, both maintaining a list of all the hospitals, doctor's surgeries, pharmacies, etc. What a wasteful duplication of effort, and potential for error, all at the taxpayer's expense. These are hypothetical examples (though not far from the truth). Now imagine the reverse. Imagine if all these useful lists were shared freely between departments and by industry. So that if I wanted to import this canonical data into my application, I could - and I could have confidence that the data was up to date, and aligned with Government. Long story short, GOV.UK Registers was shut down in 2021 without much explanation. What explanations I did hear at the time broadly revolved around lack of uptake and cost. The closure of Registers always seemed to me short-sighted, because registers felt a bit like motorways: a critical bit of national infrastructure that was an enabler for many other things, even if it wasn't immediately clear what specifically those things were (perhaps this is the real problem, and where the motorway analogy breaks down). So, I enjoyed reading today David Durant's piece explaining his perspectives on why the project failed, and some suggestions for the new Labour government on how they could make Registers a success. https://lnkd.in/dWtHmfuA

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Are you ready for PSD3, PSR and FIDA? Tribe MD Alex Reddish delves into the intricacies of the regulations set to reshape open banking, data access and security in the financial sector: https://bit.ly/45LxKYh The Fintech Times | #PSD3 #PSR #FIDA #Payments #Fintech #PayTech

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Good to see Department for Science, Innovation and Technology publish the next iteration of the UK's ID framework today, the 'Digital Identity and Attributes Trust Framework' (or 'DIATF') - this one is the 'gamma' version, or 'pre-release' version before the 'live' version next year, to support the Data (Usage and Access) bill going live. One step closer to digital ID being a legal 'thing' in the UK! #digitalID #progress

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When all you’ve got is a hammer (a centralised, £200M identity programme), everything looks like a nail (personal identity attributes from banks, mobile phone companies and email providers). I wonder if the UK Government's OneLogin system might become one of the last, great multi-million spend centralised ID schemes built in the modern age. At least some of that money is going towards understanding users. Government Digital Service (GDS) just completed important and detailed research into UK citizen identity. Link in the comments. They found that up to 10% of users don’t have enough of a digital footprint to prove their ID (a mobile phone contract, active bank account, credit cards, loans, or mortgages). Not a huge gap, but a gap. But when you dig in, it gets interesting. About those under 17: * 46% don’t have a phone number (they have a mobile but without a phone number) * 20% don’t have an email address For 18-24 yrs old: * Only 22% have that 'financial footprint' (a bank account, credit cards, loans etc.) * 16% don’t have a phone number * 13% don’t have an email address This is the generation entering the workforce. Setting up accounts. Renting, spending and helping drive the economy. Just think about that. How much today do we rely on SMS and email to prove who we are? And how much do we rely on banks and telcos and credit cards to build a digital ID? Digital wallets, including those in the EU Digital Identity Wallet, can become a smarter new way to prove who we are. And to hold *much more* digital information about us than just from the bank, telco or energy company. Our digital ID can - and should - be made up of many different parts of us. But we can't do that today because businesses can’t trust where the data came from. But that’s all about to change with Empowerment Tech. We’ll be able to prove, privately and securely: * Where our identity data came from * Who it was given to * If it’s been tampered with  * If the data attribute has been revoked That's going to be better and safer than an email account and SMS. More private and portable than checking a bank account or our 'financial footprint'. Because those approaches exclude a bunch of people. And isn't fair. We need smarter tech on the customer side. Things like verifiable credentials and digital wallets. Things like Empowerment Tech. #EmpowermentTech #CustomerFutures #DigitalWallets * * * * * If you want to know more about the future of digital customer relationships, check out the free weekly Customer Futures newsletter. Link below 👇

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Financial Conduct Authority Confirms Anti-Greenwashing Guidance and Proposes Extending Sustainability Framework Sacha Sadan, Director of Environmental, Social and Governance, FCA, said: “Confirming the new anti-greenwashing guidance and our proposals to extend the Sustainability Disclosure Requirements and investment labels regime are important milestones that maintain the UK’s place at the forefront of sustainable investment. Our good and poor practice anti-greenwashing examples will help firms market their products in the right way. We continue to work closely with the ASA and CMA to address greenwashing. “Consumers care about investing in products that have a positive impact on the planet and people. That’s why we want to boost the integrity of the market and ensure people can make informed decisions about how to invest their money.” https://lnkd.in/efFqsgrR #fintech #finance #banking #paytech #payments #fintechnews #paymentsnews

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❗Scam Alert ❗ Our #Data is showing an increase in #giftcard scams in the UK through a really, really basic #phishing attack. Scammers are claiming to be a person of authority at work and suggest the victim purchase a gift card as a surprise for a colleague (often off the back of some basic open source intelligence - promotion notification on #LinkedIn, new job role, new baby announced on their social media etc.). This scam can come by text message or via email - with the latter often mirroring an executive or managers email address almost exactly. The unsuspecting employee buys the gift cards and sends the numbers back to the boss. They find out later that the real company CEO wasn't the one that contacted them, it was a phishing scammer. Basic stuff, but we know in the #cyber world, the mass, mass majority of incidents are due to none malicious actors making a mistake. #cybersecurity #trainingandawareness #threatintelligence

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Small Xama AML update shipped a little earlier this week. We've started integrating smarter UK based address lookup and verification and this is now available to all as part of the verification journey. But making the verification journey easier for the end customer won't be the only benefit. Here's a couple of other items in the short term roadmap we are working on: ⭐ Ability to clean the existing addresses you hold against known UK addresses. ⭐ Warning whether addresses provided are residential or corporate before running an AML check. ⭐ Before running an AML check suggest whether an address might need updating or could be formatted in a way to enhance success. Improving accuracy and giving our users some certainty about their data before running thise AML checks. #amlcompliance https://lnkd.in/e7yjrmsH

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I keep being amazed by how many in my network of colleagues and friends are unaware of the level of repression and authocratic rule of our formerly democratic governments. The UK Crime And Policing Bill has been written for the former government by BigOil’s funded “Think Thanks” as a direct response to Extinction Rebellion and Just Stop Oil’s increasingly effective acts of Civil Resistance. In a nutshell, it erases the right to protest from the statute of British democratic rights. It also paves the way for the political use of the judiciary system: for instance, it allows a judge to lock away for 5 years activists who engage in acts of non violent civil disobedience (to put this in perspective: this the same sentence that rapists get). In the meanwhile, the government keeps taking money from Big Oil and disregards its legal obligation to protect its citizens from the most catastrophic consequences of the man-made environmental collapse. Similar repressive measures have been unleashed on anti-genocide protesters around the world. The same governments who choose silence in the face of the systematic murder of investigative journalists, in Gaza and in the Amazon’s forests alike. The system is shacking: we are going to take the power back. https://lnkd.in/enZUjFf3

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The ISO 20022 deadline for CHAPS has moved from Nov 24 to May 25... or has it?   It’s worth noting that Bank of England have made it very clear that they will not move the deadline beyond this point!  The Bank of England will expect banks, and their customers to work towards the deadline as if it was still the end of November. The May deadline is just a buffer for those businesses who aren’t ready. In the latest episode of our “Mastering ISO 20022” series, I discuss the updated deadline, and specifically the fact that even this extended timeline still requires banks and corporates to move quickly to prepare.  

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Another day, another data breach. It seems we have no data privacy left. I had the privilege of chairing a roundtable discussion last night on AI and its impact. Big thanks to Matthew Elstow for hosting at Oliver Bernard’s HQ in central London. One topic that was of particular concern was data; data privacy, data value, and data management in the new world we are creating with AI. On privacy, it is not obvious to me that we can protect individual user’s privacy. At a minimum, the data already lost is … already lost. And new technology to protect how existing data is stored and transmitted will face all the usual hurdles of adoption and distribution. At best, we can legislate more stringent penalties for how enterprises use and protect our data. But bad actors will continue. I’m not saying we shouldn’t try, I’m just saying we have to be realistic. However, I think we can and must invest more in using technology to protect users and their interests in a world where data privacy is not guaranteed. This approach still presents serious challenges, but perhaps more pragmatically possible with the current capabilities of AI then wishing the problem away. #aiproductmanagement https://lnkd.in/eDPDckgD https://lnkd.in/e5b2jiRf

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A 'friction-right' approach to tackling the UK's epidemic of scams - 150sec: Challenger banks operate primarily through digital platforms, and that ... What is the roadmap a challenger bank or a digital-first fintech should take ...

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From next week, UK banks will become liable to reimburse the victims of fraud by up to £85,000 per incident. It is, therefore, no coincidence that banks will be delaying the clearance of payments by up to 72 hours in circumstances where there are reasonable grounds to suspect a payment is fraudulent. I repeat: ….. “where there are reasonable grounds to suspect a payment is fraudulent”. One wonders why such payments would not be blocked as a matter of course. In the coming weeks and months we can expect to see hundreds of thousands of payments being delayed for up to 72 hours. These will naturally include payments of substantial sums to new beneficiaries. Banks will then have up to 72 hours in order to reach a decision on each payment and either authorise or decline them. Needless to say, this is all going to lead to a MASSIVE surge in interactions with end-users / customers. I very much hope that the retail banking sector is prepared for this deluge and will be able to make measured decisions in each case without letting too many to slip through the net. I suspect that the days of our “live banking system” are numbered. #bankreimbursement #appfraud #scam

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Very useful topics discussed at this morning’s UK Digital Regulation Cooperation Forum (DRCF) launch of their Digital Hub to support innovation & economic growth. The helpful collaboration between Competition and Markets Authority, Ofcom, Information Commissioner's Office & the Financial Conduct Authority aims to deliver better outcomes for industry & consumers. Interesting that Digital Identity, along with Quantum, Immersive Tech, & GenAI / Deepfakes are all on the DRCF’s mind. Yoti #digitalID

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Anyone interested in the future of public services and by obvious link the UK's economic performance should read this article by Theo Blackwell MBE and Andrew Greenway. What this and The Radical How - https://lnkd.in/euvx-vf4 by Public Digital are starting to move us towards is something I've been pondering on for a while. Despite being someone who makes a living from doing tech and data work, often in government, I don't think anything very fundamental can change further until the underpinning people/HR model of our public services change. In this sense it is about the people not the technology. Our model for people and talent that work in public services is unchanged now for the entirety of my career and I'm quite old. Whilst the world - finances, expectations and UK positioning - has fundamentally transformed. There is no incentive for bold, there are few punishments for mediocre, leadership cadres come from similar non diverse backgrounds (that's not just diversity in the usual sense of it), policy skills dominate, ministers build up little functional knowledge, required new types of talent can't work in the recruitment and HR model, most public servants stay in the sector for their entire career - I could go on. How can there be fundamental change when the people that have to deliver much of it work within such an anachronistic model. Cut taxes? Spend more money? Use AI? - fiddling whilst Whitehall has 20 person meetings for 4 hours.

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Great to see the hard work many industry bodies have been doing to create a digital assets ecosystem is bearing some fruit with the UK Chancellor Rt Hon Rachel Reeves yesterday announcing that the government is progressing on a pilot to deliver a digital gilt. (https://lnkd.in/eG5d49XF) This is a great next step after the previous HM Treasury Asset Management Taskforce, of both showing the rest of the world that UK is open for digital assets business as well as getting the industry here in the UK properly coordinated and ready to start to work with digital assets. #dlt #digitalassets #markets3.0

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Five Steps To Avoid UKGC Million £££ Fines Step 1 Interact with your customers Place a phone call, preferably immediately after registration. Give precedence to engaging with customers who have made a deposit right after signing up. During your conversation, seek to understand the customer's persona, financial standing, and gambling behaviours. Stress the importance of safe gambling, emphasising that it should be enjoyable and knowing when to cease. Step 2 Record your conversation with the customer Simply engaging with the customer isn't sufficient; it's crucial to make detailed notes of your interactions. Record the date and time of the interaction, the player's emotional state (e.g., normal, indifferent, annoyed, agitated, aggressive), recent life events they may have experienced (e.g., loss of employment, bereavement, debt issues, victim of crime, health or relationship issues), and any signs of harm you observed (e.g., financial difficulties, mental health issues, high-risk employment, ill health). Record these critical details diligently. Step 3 Review the impact of your interaction After concluding the phone call, take time to review your notes. Assess whether you need to establish deposit or loss limits, block certain products, set reminders, or schedule follow-up conversations with the customer. In some instances, closing the account may be necessary if the risk of maintaining a business relationship is deemed too high. Additionally, it's essential to gauge the impact of your call to ensure the customer's gambling behaviour isn't escalating to problematic levels. If concerns arise, don't hesitate to reach out again via phone. Relying solely on automated, generic responsible gambling emails is insufficient; proactive engagement is key. Step 4 Conduct CDD, KYC, and financial sanctions checks Avoid solely relying on customer verbal assurances and open-source data. Instead, request and scrutinise the customer's Source of Funds (SOF) and Source of Wealth (SOW) statements. Prior to new customers making their initial deposit, verify financial sanctions to meet UK Gambling Commission (UKGC) AML requirements. Step 5 Close eye on two financial metrics You need to keep a close eye on two financial metrics: deposit amounts and lost amounts. Customers who frequently deposit large sums and consistently experience losses should be your primary focus for communication. Maintain separate lists of the Top 50 depositors and the Top 50 losers. Reach out to them via phone calls, document your discussions, and consider implementing deposit and loss limits on their accounts. These five steps are crucial for safeguarding your business against hefty fines from the UKGC. Manual handling of these tasks using Excel can hinder your team's ability to scale effectively. Consider leveraging a system like Vakandi Data SGC. Reach out to us to discover how our system can streamline these processes and enable you to ensure compliance. ✉ [email protected]

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As part of the design phase for a #digitalpound. #CBDC, the Bank of England is conducting experiments and proofs of concept in collaboration with private-sector innovators and a range of stakeholders. These aim to assess the technical feasibility and technology and policy implications of potential digital pound design features. No decision has been taken on whether or not to build a digital pound. The purpose of this experiment was to assess the technical feasibility of using existing point-of-sale hardware, as currently used in the UK, to initiate digital pound payments. This involved a PoC that used #EMV standards to send #payment instructions from smart cards to POS devices, and then to an application programming interface. While the Bank did not build a digital pound infrastructure, and no real money payments were made, the experiment demonstrated the following from a technology perspective: 🔹 Existing POS terminals in the UK could, in principle, be used to initiate digital pound payments. 🔹 Those terminals do not appear to require modification in order to make digital pound payments. The experiment also concluded that it is technically feasible to implement #offline payments functionality at points of sale using existing POS terminals. But this functionality might require that an offline payments application be deployed to those terminals in order to store offline balances. Therefore, while existing POS terminals may not need to be modified to make online digital pound payments, they might need to be modified for offline payments. There are several other factors, such as operational, legal and commercial considerations, that will impact design choices around digital pound payments at points of sale. Those factors were not tested in this experiment.

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Leveraging Digital Verification will be increasingly important over the lifetime of the next UK government to improve UK productivity & reduce fraud.

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