Northern European Bankers Association

 
 
 
 
 
Overview
An association of banks in a Northern European country—a former Soviet republic—sought to enhance its reputation and to correct misperceptions about the country’s financial services sector in the United States, improve its technical capacity for financial monitoring compliance, and expand its corresponding bank relationships with U.S. banking and international financial institutions.  This goal was set in the context of recognition by the country’s political leadership that its growing emergence as a regional financial hub made proactive efforts to secure its immediate and future standing with relevant U.S. and international private and public sector officials and institutions vital.


Challenges
In the process of working individually with one of the country’s leading banks as it sought to engage with the loan guarantee program of the Export-Import Bank (Ex-Im) of the United States, Blue Star Strategies, LLC's professionals, through communication with the U.S. government, including the Department of the Treasury and other key regulating agencies, uncovered a broader issue—increased levels of inadequately monitored financial and transactional activity through the country’s banks via its Eastern neighbors—with the potential to cause harm to the country’s banking sector as a whole and jeopardize its reputation and status in the U.S. and the world as a banking hub.  In seeking to identify potential remedies to this situation, the team noted two interrelated challenges:
 
1) A lack of robust relationships, programmatic engagements, and lines of communication between the country’s public and private institutions and their counterparts in Washington; and
2) A lack of knowledge in—and support from—the U.S. regarding the country and its democratic, economic, and financial progress since its independence from the U.S.S.R. more than ten years prior.

Strategic Recommendations
Blue Star Strategies, LLC's professionals proposed to develop and implement an engagement strategy and program to strengthen the bilateral and working relationship between the country’s banking industry and key political leaders, decision-makers and program implementers in Washington, including in Congress, executive branch agencies, international financial institutions, and key private sector financial institutions and banks.  To do so, the firm recommended a strategy of partnering with the U.S. government, U.S. financial regulators, and U.S. banks to develop and implement state-of-the-art financial monitoring procedures, mechanisms, and compliance standards—including anti-money laundering and counter-terrorism financing (AML/CTF) protocols—with the goal of building a robust, transparent and cooperative relationship for the country and its banking industry with the U.S.  In conjunction with this recommendation, Blue Star Strategies, LLC proposed to work to build and expand the industry’s reputation by leveraging its cooperative potential with U.S. banks—through increased corresponding bank relationships—and with non-governmental financial associations.                    

Program Elements
Key programmatic elements included: identifying, partnering with and educating key players among international financial institutions (IFIs) and U.S. federal and state leaders, and facilitating engagement for the country’s financial institutions, its leaders—ministers and Washington embassy officials—and representatives of the bankers association[1]; initiating, monitoring and coordinating substantive programmatic engagements with U.S. counterparts for leaders of the country’s banking industry, political structure, and financial institutions to strengthen its AML/CTF procedures; developing working sessions, seminars, and conferences where experts and stakeholders from both sides of the Atlantic gathered to discuss issues, resolve concerns and enhance understanding of respective business practices and regulatory frameworks; initiating and sustaining partnerships with key industry and consulting organizations, including the American Bankers Association (ABA), Bankers Association for Finance and Trade (BAFT), American Bar Association Rule of Law Initiative, Institute of International Bankers (IIB), and Promontory Financial Group; educating and initiating and sustaining relationships with U.S. banks, including JP Morgan, GE Capital, Deutsche Bank, HSBC, Citigroup, Bank of America, and Wachovia-Wells Fargo; and monitoring and influencing U.S. and non-U.S. regulatory and legislative developments affecting the banking sector.

Results
Blue Star Strategies, LLC’s efforts successfully changed the reputation of the country and its banking sector and resulted in the creation of a multi-varied network of public and private sector leaders committed to serious and sustained engagement and personal cooperation and communication with the bankers association and the country’s leaders on the issues of concern to the industry.  The substantive programmatic aspects of the strengthened bilateral relationship with the U.S. remain in robust force to this day.  During the engagement, the firm was also able to successfully respond to new challenges, including anticipating and educating Congressional leaders and staff regarding draft legislation—and working within the created network to develop alternative language—that inaccurately identified the country in a list of bad actors and back channeling information with the U.S. government and IFIs regarding the country’s response to the global financial crisis, which affected the country acutely.

 



[1] Key engagements included: Congressional Committees – Senate: Banking, Housing and Urban Affairs; Finance; Foreign Relations and House: Financial Services and Foreign Affairs; Departments of Treasury and State, National Security Council; Ex-Im Bank; International Monetary Fund (IMF); International Finance Corporation (IFC); and European Bank for Reconstruction and Development (EBRD).