John Watkins, Managing Editor, Global Custodian: Hello, and welcome to this roundtable discussion from Global Custodian – Unlocking the Future: Transforming Custody Account Opening with Technology.

I’m John Watkins, Managing Editor of Global Custodian, and I’m delighted to be joined by a panel of experts.

Today, we’re discussing what is something of a tale as old as time in the custody space – a manual, heavy, complex, and somewhat clunky process that’s crying out for automation and technological innovation.

We'll be exploring how leveraging technology can help overcome inefficiencies in the account opening process – inefficiencies caused by lengthy timelines, repetitive document submissions, and complexities stemming from regulatory and market-driven requirements.

Judging by the interest we've seen in this session, it's clearly a particularly pertinent issue for our audience.

So, some quick introductions. Joining me today:

• Suren Sankar, Managing Director, Global Custody, State Street
• Oliver Maxwell, EMEA Head of Regulatory and Compliance, S&P Global
• David McNally, Global Head of Product Management, Securities Services, Deutsche Bank
  

Welcome, all.

All: Thank you. Thanks for having us.

John Watkins: Just a couple of housekeeping notes before we begin.

We are live right now, so do send in your questions as they come to you. We’ll aim to answer them during the discussion or during the 10 to 15 minutes allocated for Q&A at the end.

We’ll also have some polls appearing on screen throughout the conversation to help guide our discussion. In fact, our first poll should be coming up now:

Poll: What do you consider the biggest challenge in the account opening process?

John Watkins: David, while our audience is responding to that poll, could you start us off by outlining, from your point of view, the challenges and pain points of the account opening process?

David McNally, Deutsche Bank: Thanks, John. I’ll try – and we’ll see whether what I say matches up with what the audience thinks.

Let me start by saying that the account opening process in the custody market – particularly – is, quite frankly, more complex than it should be.

Anyone who has been through it knows that. I’m sure many of the audience will feel the same.

It’s not just one challenge – it’s an entire web of complexity: regulatory, operational, and technological hurdles that slow things down, frustrate clients, and increase costs for everyone involved.

Looking at the poll results, lengthy timeframes are clearly something people feel strongly about – so it sounds like we’re on the right track. We’ll see how the percentages evolve, but when one option jumps ahead like that, it usually stays there.

So – time. But maybe let’s talk a bit about regulations to start with. Every market has its own set of rules.

Each market has its own compliance requirements—and in some cases, very, very high documentation standards. Regulators are rightly focused on protecting the integrity of the financial system. But the sheer volume of compliance obligations—KYC, AML, FCA regulations, local tax laws, a myriad of frameworks—means that onboarding clients is no longer, if it ever was, a simple administrative task. It has become a full-scale regulatory exercise.

Because regulations evolve constantly, firms like ours must evolve as well to keep up. And often there isn’t clear or immediate guidance on what best practices are involved. This creates delays, adds complexity, and ultimately slows clients’ access to the market—something we all want to improve quickly.

A good example of this is the practice of the Designated Depository Participant, or DDP, in India. The DDP function is a critical regulatory mechanism for onboarding foreign investors into the Indian securities market. It was introduced by SEBI, the local regulator, and it creates obligations for foreign investors to obtain a license or registration from the regulator.

Ten years ago, this process was managed by the regulatory bodies themselves. Now, it’s the responsibility of the local custodian. A clever move on the part of the regulator, perhaps. At Deutsche Bank, we now evaluate whether an applicant meets the eligibility criteria for foreign investors, and ensure they adhere to standards around KYC, AML, and other relevant regulations.

This is a prime example of how an additional layer of scrutiny is introduced. As one of the most prominent custodians in India, we’ve had to develop the expertise to understand these rules, navigate them, and create structures and processes to manage those requirements. DDP is a great illustration of the pivotal role custodians play in ensuring the Indian market remains accessible for foreign investors.

And, if I may say so, we think we do that rather well at Deutsche Bank.

Section 2
Moving on, let’s talk about another layer of complexity—manual processes. Despite the strides our industry has made in automation, custody account opening remains heavily reliant on paper forms, wet signatures, and manual data entry.

And every time a document needs to be scanned, verified, or re-entered into another system, the risk of human error is introduced. That lack of standardisation—across markets and even across client behaviours—makes it incredibly difficult to integrate workflows efficiently.

And that can be significantly influenced by location. I mentioned India earlier, but that’s just one example. This inconsistency makes it hard for institutions to scale operations. Not impossible—but definitely harder.

Related to that is documentation. I mentioned it a moment ago, and in my view, it’s one of the biggest pain points in the entire industry. The sheer volume of paperwork is staggering—legal agreements, corporate structure documents, tax forms, regulatory disclosures. All of it has to be collected and verified.

In some cases, these documents need to be notarised or apostilled, depending on the jurisdiction. And in certain markets, they must be submitted in physical form and hand-signed. I think you're getting a sense of what I’m saying—it's extremely intensive.

The impact on client experience really can’t be overstated. Looking back to the poll earlier, it’s clear the audience agrees—these documentation requirements are a major factor behind long onboarding timeframes and delay access to markets.

Now, if you're a global investor looking to access multiple markets through different custodians and networks, you not only face all the hurdles I’ve mentioned, but you also run into fragmentation. That means potentially inconsistent solutions to the same underlying problems.

It’s opaque. It’s frustrating. There's a lack of transparency—clients often ask, “Where is my application? Where is my document? Where am I in the process? Who needs to approve the next step?”

These kinds of inefficiencies don’t just slow things down—they represent lost opportunities for clients. And that’s a real problem.

Just two more thoughts before I hand over to Ani. The challenges don’t stop there. I mentioned multi-market asset access, but cross-border issues add further complexity—different time zones, language barriers, country-specific restrictions, tax implications—all of that has to be navigated.

Section 3
And every time a document needs to be scanned, verified, or re-entered into another system, the risk of human error is introduced. That lack of standardisation—across markets and even across client behaviours—makes it incredibly difficult to integrate workflows efficiently.

And that can be significantly influenced by location. I mentioned India earlier, but that’s just one example. This inconsistency makes it hard for institutions to scale operations. Not impossible—but definitely harder.

Related to that is documentation. I mentioned it a moment ago, and in my view, it’s one of the biggest pain points in the entire industry. The sheer volume of paperwork is staggering—legal agreements, corporate structure documents, tax forms, regulatory disclosures. All of it has to be collected and verified.

In some cases, these documents need to be notarised or apostilled, depending on the jurisdiction. And in certain markets, they must be submitted in physical form and hand-signed. I think you're getting a sense of what I’m saying—it's extremely intensive.

The impact on client experience really can’t be overstated. Looking back to the poll earlier, it’s clear the audience agrees—these documentation requirements are a major factor behind long onboarding timeframes and delay access to markets.

Now, if you're a global investor looking to access multiple markets through different custodians and networks, you not only face all the hurdles I’ve mentioned, but you also run into fragmentation. That means potentially inconsistent solutions to the same underlying problems.

It’s opaque. It’s frustrating. There's a lack of transparency—clients often ask, “Where is my application? Where is my document? Where am I in the process? Who needs to approve the next step?”

These kinds of inefficiencies don’t just slow things down—they represent lost opportunities for clients. And that’s a real problem.

Just two more thoughts before I hand over to Ani. The challenges don’t stop there. I mentioned multi-market asset access, but cross-border issues add further complexity—different time zones, language barriers, country-specific restrictions, tax implications—all of that has to be navigated.

Section 4
And all of this—everything I’ve just mentioned—contributes to operational risk.

On top of that, technology itself, dare I say it, is also part of the problem—even though it's potentially part of the solution too. I know we’re going to spend some time discussing that later on.

But many firms still operate on legacy systems that don’t integrate easily into modern onboarding solutions. So what we’re left with is a process that’s slow, inconsistent, often very manual, and highly fragmented. It’s frustrating.

The good news is—it doesn’t have to be like this.

Moderator: Yes, we’re going to get on to the good news shortly. Maybe we’ll leave it there for now.

Everything you’ve said completely justifies why we’re having this conversation. Your opening comment—that it’s more complex than it needs to be—sums things up perfectly.

So, bringing in the global custodian perspective now—do you see common challenges?

Suren Sankar: Yes, and picking up on some of the points David just mentioned, the way I look at account opening and the ecosystem is that there are three primary players. You have your buy-side firms and their appointed investment managers. You have your global custodians. And you have your sub-custodians and agent banks.

The pain points that were listed in the poll? They’re all relevant, and they affect all three participants in the ecosystem.

What I find really interesting is how these pain points are interconnected. The audience voted for “lengthy timeframes” as the top issue, but I’d argue the other pain points actually contribute to those long timeframes.

Take bifurcated processes, for example. One of the challenges we hear from clients every day is that they deal with multiple custodians. That means different processes and different systems they have to engage with.

From a global custodian perspective, we face the same challenge. When we work with agent banks across multiple markets on behalf of clients, we experience that same bifurcation.

So, what you end up with—as David said—is a very manual, paper-based, archaic process. And that feeds into the second issue: lack of transparency. If you don’t have a digitised process, it’s going to be opaque. There’s no visibility for the client.

That results in a lot of manual touchpoints—clients chasing global custodians, custodians chasing agent banks, and back again. It moves in a slow, linear fashion.

To me, all these issues are interrelated. And they all come back to the three main participants in the ecosystem. These pain points ultimately culminate in the long timeframes we see in the market.

Oliver Maxwell: Yes, I completely agree. Unpacking “lengthy timeframes” is a big box—and as we've seen, it’s a symptom of deeper structural issues.

The documentation situation in our industry is, frankly, crazy. It's 2025, and our reliance on paper-based documents is still astonishing.

To bring that to life a bit—in our ecosystem, we collect over 300,000 documents a year. These range from one or two pages to hundreds, sometimes even thousands of pages per file.

Now, once a document gets to stage three—or hits Deutsche Bank, for example—that document is reviewed from page one to the last by at least two different people in separate teams. That’s hugely inefficient.

You’re talking about hundreds of hours spent just manually reviewing documentation. What we really need is to reimagine how we use documents and how we extract data from them. Because if you can extract the data, you don’t have to rely on a manual review—you can streamline the process and reduce timeframes.

Another big issue is the lack of transparency around what documents are required at onboarding. That’s when you get emails going back and forth, which get lost in shared inboxes, and people just don’t have clarity or understanding of what's needed.

So, we need to move toward a more data-led onboarding process.

JW: Brilliant, thank you all for setting the scene. Before we get to the punchline of how you can fix this, I want to ask: Why haven't some of these challenges been tackled already?

I know this industry often defaults to, “Well, this is just how we’ve always done it.” But is that the only reason? Or is it more to do with complexity, legacy technology, or something else?

Yes, happy to jump in on that. And I believe we have another poll question coming up on this, which will help tailor the conversation.

So—why has the pace of change been so slow?

SS: The first thing I want to say is that change is happening in the industry. It’s not that we’re standing still. The issue is the speed of that change.

Global custodians, sub-custodians—we all recognise the pain points we’ve discussed, and the lengthy timeframes clients are dealing with. The problems are well understood.

There’s a lot of work being done to digitise, normalise and standardise processes—to bring account opening into the 21st century.

But there are three broad reasons why I think progress has been slower than we’d like.

The first is the sheer volume of data required for account opening...

As we started the process of digitising data at State Street, one of the first things we realised was just how many data points are required across all the jurisdictions our clients operate in.

We identified over 1,200 unique data points across those jurisdictions. So you can imagine—standardising, normalising and digitising that volume of data is a mammoth effort in itself.

The second challenge is something David mentioned earlier: market complexity. No two markets are the same. You have documentation markets and non-documentation markets. Some accept digital signatures, others require wet ink. Some operate omnibus accounts, others require segregation. Every market has its own unique nuances, which makes creating a single global solution extremely difficult.

And layered on top of that are the regulatory changes. These markets are constantly evolving, and as custodians—both global and sub—we’re responsible for ensuring our data and policies align with the most current market standards.

The third challenge is more structural. There are three key players in this ecosystem: buy-side clients, global custodians, and sub-custodians. All three have been on individual journeys to improve account opening processes over the past few years. That’s a positive—it shows universal recognition of the problem. But the downside is that much of this progress has been made in silo.

As a result, we’ve ended up with very different processes across the ecosystem, which then need to be stitched together. At State Street, one of our focuses has been interoperability—ensuring we can interface with clients however they prefer.

If they want to use a dedicated UI, we provide that. If they prefer to go through ecosystem integrators like S&P, we’ve built those connections. And if they want a direct API link, that’s available too.

So, in summary, I think there’s no lack of commitment to advancing account opening. But the challenges—massive data requirements, market differences, regulatory shifts, and a fragmented approach—mean that the scale of work required is significant.

JW: Brilliant—thanks for that. And Ollie, maybe I’ll bring you in here?

OM: Yes, I completely agree with everything just said.

It really comes down to desire and resources. This kind of transformation demands significant investment in time and effort. And we all know how stretched these teams are—they’re already running flat out just keeping day-to-day operations moving.

When it comes to prioritising big change projects, then the question becomes: who has the budget?

…then budget comes along, and teams embark on transformation programmes—but then new regulations emerge, and the focus shifts again. Suddenly it’s about how to adapt systems and processes for compliance, and attention is diverted.

So I think system architecture has been a major blocker. But I also agree with the point that the industry is waking up. People are realising we can’t keep processing things via email, spreadsheets and paper-based procedures.

That also connects to the regulatory change challenge. If a new rule comes in and your firm has to wade through dozens of paper-based procedures to implement that change, it’s virtually impossible. Ensuring risks are properly addressed in such a scenario is incredibly difficult.

We need to encourage the industry to look around—see what other solutions are out there. Rather than building bespoke client portals, which just add to the fragmentation problem. One firm builds one portal, another builds theirs, and clients are left juggling multiple siloed systems. That’s not a good client experience.

This is where third-party vendors and shared applications can help tie things together across the industry.

JW: Great points. David, we’ve heard a lot about market nuances and regulatory change—both of which you highlighted earlier with the example of India. Anything you’d like to add on the topic of why the pace of change has been so slow?

DM: Yes, I think it’s no surprise that half of the audience in our poll cited market nuances as a primary cause of delay. But what I found interesting was how few people mentioned cultural resistance—which is actually quite encouraging.

That said, I do think it’s worth acknowledging. Financial institutions, particularly custodians, are by nature quite conservative—and rightly so. The penalties for non-compliance with regulations are significant, so a cautious approach is often necessary.

This might not be "cultural" in the traditional sense, but it certainly influences decision-making and contributes to the slower pace of innovation in this space.

However, I believe we’re entering a new era now. We're in a rapidly evolving technological environment, which is really exciting. And if I were to infer from the audience’s responses, I think they’d agree: cultural resistance is no longer the primary blocker.

That said, we still have to acknowledge the weight of legacy processes and infrastructure, which remains a huge factor. The systems and ways of working that have been entrenched over decades are hard to shift.

Ollie, you've already referenced this—the cost of change is significant. Modernising systems and re-engineering workflows requires substantial upfront investment, and that can carry a pretty hefty price tag.

That doesn’t mean it’s not worth doing, but it certainly helps explain the slow pace of change. Justifying those investments can be tricky, especially when the return on investment might not be immediate or even clear-cut.

There’s also, I think, a lingering fear of disruption—that making too big a change might unintentionally introduce new issues. Personally, I don’t agree with that mindset, but I do acknowledge that it exists.

OM: Do you think there’s a fear of technology, specifically? That it might impact people’s jobs or alter their roles in ways they’re uncomfortable with?

DM: From my experience—and speaking about the teams I work with—the answer now is: no. Even colleagues heavily involved in the manual work understand that new technology can actually improve their jobs. It’s seen more as a development opportunity than a threat.

OM: Yeah, I agree. That’s something we hear too, even as a vendor. Sometimes the first instinct is to see technology through a negative lens—people worry about what they might lose rather than what they might gain. But the positives are compelling: more value-added tasks, more fulfilling work, and the removal of mundane, repetitive steps.

DM: Exactly. And the widespread use of technology in our personal lives is finally filtering into our professional expectations. That’s helping accelerate a shift in mindset and improve openness to change.

OM: I completely agree. But I’d also say this: the evolution of tech in our industry has had some false starts. People have tried new platforms or systems that overpromised and underdelivered. That breeds scepticism.

The key is to stress-test solutions. Run proofs of concept, pilot programmes, and adapt tools so they genuinely work for the business. When people see that a new system is fit for purpose, you start to win hearts and minds.
…and those are the people who actually end up driving adoption. That’s the approach we’ve taken, and it’s worked really well.

DM: May I add one more thought before we move on?

JW: Absolutely.

DM: It’s not on the poll list, but I think a major hurdle is customisation. Clients and markets all have their own sets of requirements, and while standardisation sounds great in theory, in practice it’s very hard to deliver.

The variability between markets and client types makes a "one-size-fits-all" approach almost impossible. That’s a perspective shared by many in the industry.

This makes streamlining processes really difficult, even with the best intentions. Striking the right balance between configuration and customisation is especially tough once we start looking at potential technology solutions—which we’ll come onto shortly.

But this need for flexibility really contributes to the pain points.

JW: Yeah. I said we’d come onto solutions in a bit, but one thing that’s striking as we talk through this—and I’m learning a lot myself—is how rarely frank conversations like this happen at industry events.

Ollie, how often do you see this level of candour in discussions at conferences or behind the scenes? It feels like most conversations stick to generic themes or rehearsed talking points, rather than digging into the detail like we are here.

OM: I think you’re right—this stuff is discussed, but it’s usually done in silos. And I truly believe that to solve these problems, we need more collaboration. We need open, honest dialogue between all the players in the ecosystem.

There are governing bodies out there trying to build standards and drive standardisation, and that’s a positive step. But honestly, I’ve been in this industry for over 24 years, and these conversations keep happening year after year.

Everyone agrees in the room… and then walks out and reverts to thinking, “Well, we can just do it better on our own,” or “We don’t need to conform—we’re the best custodian already.”

But I think the penny is starting to drop. People are starting to realise that we have to embrace technology, because the pace of innovation outside our industry—particularly with AI—is phenomenal.

Right now, for every one calendar year, we’re seeing four years’ worth of innovation, and that’s only going to accelerate. If the industry doesn’t start changing now, we risk being left behind.

And there are some fundamental changes that need to happen...

The data in the industry needs to be 100% high quality. If you layer innovation on top of bad data, you're just going to get bad results.

Take AI or ChatGPT, for instance—they’re brilliant. But if the input data is poor, you're never going to get the outcomes you want.

So, there’s still a lot of work to do. And again, it's going to require investment and commitment from across the industry. But if we can do this collectively, we can really start to transform the ecosystem.

JW: Absolutely. And I don’t want to just pat ourselves on the back here, but I think these targeted conversations are crucial. We often talk about “innovation” as a broad theme—David, I know you’ve been on innovation panels before—but actually diving into specific pain points like account opening makes it much more meaningful.

OM: Agreed. It comes down to education and curiosity. What’s out there? What are we missing? Some parts of the industry are moving faster than others. One of our platforms—Request for Amend—has really revolutionised how trading agreement data is added for new funds.

Investment banks have been using it for the last eight years, shifting the process away from expensive legal teams to more operational workflows. But when we brought it to custodians, there was resistance. Even though the benefits are the same.

So it becomes about understanding what’s already available, how to connect the dots, rather than trying to build something from scratch every time.

JW: Yeah, I’d love your thoughts on that.

SS: I completely agree. We’re focusing on account opening here, but honestly, the same issues appear across the board—in income tax, corporate actions, post-trade settlements. There are digitisation and utility efforts across those areas too.

Some of those areas are easier to solve, but account opening is trickier because of the sheer number of data points, regulatory considerations, and market nuances.

That said, the appetite to fix this is absolutely there. It’s just taking a little longer because it’s a more complex puzzle.

But I do believe—and this is important—that over the last few years, we’ve seen tremendous progress. Across the industry, among our peers, even at the agent bank level, a lot of foundational work has been done.

And I genuinely believe that this year, we’ll start to see a real shift in the way account opening functions, especially with new utilities and platforms now being stood up.

…of these utility interfaces now being made available. So I think this topic is incredibly timely. If we’re having this same conversation next year, and the same pain points still exist, then something’s gone seriously wrong.

JW: So, 2025: the year of account opening transformation? We’ll hold you to that. David, anything you’d like to add?

DM: I agree with everything that’s been said. I’d just like to double down on the data point—because that’s foundational. I know we’re about to discuss solutions, so I won’t front-run what my colleagues may say, but I do think there’s enormous potential in how we manage and utilise data.

Of course, that moves us toward cloud-based technologies, which is the obvious direction. But I’ll pause there for now.

JW: Perfect, let’s move on. And a quick reminder to our audience—if you have questions, please do send them in. We’ll incorporate them into the conversation where we can, or cover them at the end.

Before we dive into the next question, I believe we have Poll 3. If we could bring that up, please…

“What do you see as the biggest barrier to adopting new technologies in the account opening process?”

JW: Ollie, back to you. You set this up well earlier—so, we’ve talked through the problems and some potential solutions. Now the big question: how do we actually fix this? And how can all the players collaborate to make it happen?

OM: Let me take this from a slightly different lens.

Last night, I was chatting to my wife—she’s an art teacher—and she asked what I was doing today. I said, “I’m doing a webinar on global and sub-custodians and account opening inefficiencies.” She just looked at me blankly.

So I explained it using something a bit more relatable: takeaway delivery.

If I want to order food, I use Deliveroo. Now, Deliveroo doesn’t own the kitchens or the ingredients, but they provide the infrastructure and connectivity to the restaurants that do. They handle payments, they give updates—"your order’s been accepted," "it’s in the kitchen," "the rider’s on the way," etc.

Menus are digitised. I don’t need to dig out a printed leaflet. I don’t need cash because it’s all handled via card payments. I get real-time transparency.

Now, imagine if I had to email my order and wait two weeks for a response. And then they emailed back asking how many peppers I wanted in my curry… and another two weeks went by before my food arrived. That would be ludicrous. But that’s essentially where our industry is today.

So the big question is: why are our expectations higher in our personal lives than in our professional lives?

If we boil it down, despite regulatory and market nuances, the solution is simple:

1.  Create a flexible and agile custodial network that complements and enhances existing systems through API connectivity.
2.  Reimagine documentation. Use technology to extract key data points and become data-led.
3. Push for standardisation where possible, while also maintaining the flexibility for firms like State Street and Deutsche Bank to tailor to their unique legal and compliance needs.

And ultimately, it’s about using technology to create agility.

…and flexibility—so when regulatory demands change, the infrastructure can pivot immediately to accommodate those changes.

You shouldn’t have to ask, “Which of my clients are impacted? How do I remediate? How do I get new or expired documentation signed?”

And then there’s transparency. We want to eliminate back-and-forth emails by getting the data right the first time.

We’ve been helping the industry address these challenges since 2007, and it’s all about forward thinking. Organisations like State Street and Deutsche Bank are leading the charge.

If we get this right, the benefits are clear:

• Client satisfaction will skyrocket.
• The risk of incomplete or non-compliant processes will all but disappear.
• You’ll be able to service more clients.
• Your workforce will be more productive and far less frustrated.
  

So, the call to action is simple:

We need to embrace change, be brave, be curious, and look around.

Don’t accept hard processes—because you wouldn’t in your personal life, so why accept them in your professional life?

And one more thing—we often get stuck on the complexity. But instead, let’s focus on the 80% that’s common across cases.

Automate the hell out of the 80%, and free up time to solve the 20% that’s truly complex. That’s where the real success lies.

JW: Yeah, great stuff. Fantastic. And your wife now knows more about sub-custody than most people!

I think we’ll be borrowing your Deliveroo analogy in the future, Ollie.

SS: You made a great point on the 80/20 rule.

And I see from the poll that budget constraints have come out on top.

As global and sub-custodians, we’ve made serious commitments to investing in account opening over the past few years.

We’ve largely got our houses in order, and I think over the course of this year, we’ll start to see real progress.

I think the buy side, however, often feels like they have to do a lot of work just to participate.

There’s a fear: “Do we need to make huge changes to interact with these utilities?”

In reality, it’s not as overwhelming as many think.

When we sit down with buy-side firms, they all want to interact in different ways:

• Some prefer a user interface built by us.
• Others are multi-custodian and use ecosystem integrators like S&P to connect to us and others.
• And some have their own systems and just want API point-to-point connectivity.
  

The point is, we’ve built these solutions to be interoperable.

So, the upfront costs for the buy side aren’t necessarily as high as some assume.

Much of the groundwork has already been done between global custodians and agent banks to make participation easier.

DM: Brilliant. That’s a tough act to follow, but let’s move to some specific use cases and technologies that are enabling this change.

While we’ve all agreed interoperability and collaboration are key, let’s put that into practice.

The first example I want to highlight is RegTech.

This is an area that has gained a massive amount of momentum in recent years…

There are already lots of very good tools that are enablers in this respect. We’ve talked about the sheer amount of complexity in the custody market. Without adding more layers, RegTech is a way of simplifying this.

For example, AI-driven platforms that can scan and interpret regulatory updates—these are already being deployed. They help flag regulatory changes across multiple jurisdictions like the SEC, ESMA, FCA, and so on. Automating this is an obvious use case.

Smart contract technologies are another. They can enforce compliance rules throughout the onboarding process.

Let’s not forget automated KYC and AML screening. Machine learning is already being used to cross-check client data. As retail customers, many of us can open a bank account with just a scan of a driver’s licence—it's quick. The goal is to apply similar technology in the institutional space, even if it’s more complex.
These are examples of technologies that are enablers.

And on cloud—we’ve touched on this already—it ties back to interoperability. The industry has been slow to move to the cloud, but at Deutsche Bank we’re committed to transitioning as much of our custody business as possible. Cloud offers scalability, security, and enables seamless integration in real time. It reduces costs around computing, development, and change, and it speeds up innovation.

It also addresses another major problem—data silos. Information is often stored across many systems. But unless the data is high integrity and properly controlled, you can't just shift it into the cloud and expect results. Still, cloud solutions can be a game changer, and we've invested heavily in this area because we believe it's the future of custody.

OM: On the data point—what we're seeing is convergence between fund-to-broker onboarding and custodian onboarding. They used to be entirely separate processes, handled by different teams, even though they often require the same data. So the client rightly asks, “Why am I providing the same information again?”

The issue is legacy infrastructure. But moving to cloud gives you more freedom in how you manage and share data. We’ve seen this in practice—for example, with our work with ISDA since 2012. That stopped the endless exchange of spreadsheets and manual rekeying of information.

So when it comes to buy-side adoption, if you make it simple, they'll use it. That’s where real efficiency gains happen—downstream as well.

SS: Exactly. And having data in a single place—whether it’s in the cloud or a centralised system—lets you run checkpoint processes across workflows. For example, running KYC/AML in parallel with other onboarding steps, but only releasing the account once those steps are complete.

We did this last year and it significantly reduced account opening time. Before, everything had to happen sequentially. But parallel processing with clear checkpoints changes the game.

But it all comes down to data. If you can get the right data, extract it accurately from documents, and get it right first time, you can solve a lot of problems. The challenge is getting to that point. And to do that, we all need to come together—custodians, sub-custodians, vendors, and the buy-side.

JW: Can I get one of you to comment on the audience poll? Budget constraints came up as the biggest barrier. Was that expected?

OM: Budget constraints are always a big one—on two fronts. Internally, you’re allocated a set budget, but if costs increase or priorities shift due to regulatory changes, the funding can disappear. From a vendor perspective, there’s often hesitation to invest. That’s why we focus on clearly articulating the return on investment and the benefits. 

If you do that well, the investment usually follows.

DM: Exactly. That’s why we’re strong proponents of cloud technology. Budget cycles are unpredictable, but cloud offers flexibility. You reduce your on-prem cost base, and you can scale up or down depending on your investment appetite and client demand. It’s adaptable.

JW: And good to see that “resistance to change” came in low on the list. Hopefully this really is the year for onboarding transformation.

SS: We had a question come in asking if we’d covered standardisation of data points and consistency in labelling—so all parties speak the same language and clients don’t have to interpret different terms from different providers.

OM: Yes—we have. What we’ve done is build a system that allows users to customise the labels they see—whether they prefer “legal entity,” “entity,” or “company name.” The central data model stays consistent, but each party can view the field as they prefer. That reduces internal system changes and workflow friction. It’s all about configurability through technology.

SS: Exactly. We can’t wait for an industry-wide data dictionary to solve this—we need to be pragmatic and flexible. That’s the only way to make progress now.

OM: Across the ecosystem, we need to create standardisation. But it's also about accepting that we all call the same thing by different names. So we have to build that data mapping ourselves. That’s exactly what we’ve done—we have our core data model, and when information comes in, whether from agent banks or clients, we map and translate that data so it aligns with our structure.

JW: Thanks for that. We’ve had another question come in—this time about MT599s. In the sub-custodian space, when receiving account opening instructions via MT599 from custodians, the information often lacks consistency and opens the door for interpretation. Is this something we can address at an industry level? Maybe through Swift or a vendor solution?

DM: Great question. I think the answer is yes. As we've discussed, this all boils down to standardisation of data. But rather than wait for regulators or industry bodies to enforce this, we each need to invest in standardising our internal data models. That includes understanding our own data controls and lineage—this is foundational to making the ecosystem work.

SS: I agree with David. Everything we’re doing is pointing towards greater standardisation. As we evolve account opening processes, we’ll naturally start to identify inefficiencies. For example, markets that still require wet signatures. If the buy-side, global custodians, and sub-custodians all move in the same direction, we can start to address those inefficiencies and even lobby for regulatory change where current practices don’t make sense.

JW: Another question—how do we convince sub-custodians to adopt smart contracts when many still demand hard copies?

DM: I don’t think sub-custodians need convincing. We’re already implementing smart contract technologies where we can. The issue is more about practical constraints—development time, budgets, and regulatory requirements. In some markets, a wet signature is still mandated. But that doesn’t prevent us from using digital contracts or automation elsewhere in the value chain.

OM: Exactly. And not all sub-custodians are large global players like Deutsche Bank. You have a mix, including smaller local institutions. Also, it’s not always the sub-custodian dictating requirements—it’s often the local market practices or regulatory rules.

SS: Yes, and that’s why, as we develop these ecosystems and drive adoption across all participants, we’ll be in a better position to pressure regulators to modernise outdated processes. It’s about collective influence.

JW: Great. Thanks for that. We’ve got five minutes left, so let’s go around for some closing remarks. What do you think can change in the short term from everything we've discussed today, and what do you hope to see change?

SS: Sure. I’d echo some of the points already made. Account opening shouldn’t be a differentiator. We don’t accept this level of complexity in our personal lives—why should we in custody? So for me, building out a utility, driving standardisation and normalisation—that’s what I want to see more of.

And I’d really like to see more collaboration. Historically, there’s been too much siloed development and strategy. But in the past few years, I’ve seen real progress—more cooperation between firms, because again, account opening is not a competitive advantage. The real advantage comes when we all work together and pull in the same direction.

JW: Great to hear. And same question to you, Ollie. What can change now, and what do you hope to see?

OM: I think we have to measure progress in the short term. Continuous improvement is key. Like your social feed—you solve one piece, move on to the next. Start with data collection, then move to processing and output. That momentum matters.

We’re at a point where we really can change the whole process—but it’ll take all of us. And I hope that this time next year, we’ll look back and say we cracked the first phase, that we came together and made it happen, rather than thinking about competitive advantages that can hold us back.

JW: Thanks, Ollie. David, final thoughts from you?

DM: Thanks. Two points from me. First, while we've focused on custody account opening, many of today’s audience will be asset owners or managers. They expect the same seamless experience whether they’re onboarding for custody, FX, cash management, market access, or securities trading. So everything we’ve discussed should really be applied across those product areas too.

Second, the technologies we talked about—RegTech, cloud, enterprise data management—are not nice-to-haves. They are essential to stay competitive. And these aren’t one-time investments. Yes, we’ve heard about budget constraints, but these are long-term priorities that have to be funded and prioritised. If the industry can collaborate effectively, as Ollie said, we will see positive change.

JW: Absolutely. And if I had to pick one quote to finish on, Ollie, yours sums it up perfectly—be brave, be curious. Thank you everyone for joining. If any of your colleagues missed the session, we’ll be posting it on the Global Custodian website for on-demand viewing.

Ollie, David, Suren—thank you both very much for your insights and conversation today.

All: Thank you.