Description of the goods or services required
The Bank of Greece (the “BoG”) has requested support from the European Commission under Regulation (EU) 2017/825 on the establishment of the Structural Reform Support Programme (“SRSP Regulation”) to assist the BoG in establishing a Regulatory Sandbox to facilitate FinTech and Innovation in Greece (the “Project”).
The Project is funded by the European Union via the Structural Reform Support Programme and implemented by the Local Currency and Capital Market Development (LC2) team of the European Bank for Reconstruction and Development (the “EBRD”), in cooperation with the European Commission’s DG REFORM.
Financial Technology (FinTech) is an important tool to improve the efficiency of the financial system. FinTech comprises a variety of products, applications, processes and business models that have transformed the traditional way of providing banking and financial services, which can be of great benefit to the Greek society.
As the FinTech sector in Greece grows, it is important that all parties involved not only pay close attention to technical, regulatory, policy, and legal considerations, but also monitor its growth and better understand its impact. There is a strong need to fully identify and understand the potential of FinTech in Greece, as well as the risks associated with its adoption; and to develop a robust and flexible regulatory framework, that would facilitate further growth and legitimate solutions, providing at the same time a sufficient level of consumer protection.
To this end a “regulatory sandbox”, as a live testing environment can bring positive results, given the complexity of applying the Greek legal and regulatory framework surrounding financial services on technology driven financial products and business models, when in balance with the need to ensure consumer protection and to promote effective competition.
The general objective of this Project is to contribute to institutional, administrative and growth-sustaining structural reforms in Greece.
The EBRD now intends to engage a consulting company (the “Consultant”) in order to assist and support the BoG with the implementation of the following indicative activities:
• review the FinTech legal and regulatory environment in Greece;
• prepare a clear path of action for the BoG as to enable the operation of the regulatory sandbox;
• support the BoG in operationalisation of a regulatory sandbox;
• organise a kick-off/launch event and undertake the associated tasks;
• present the findings from the operation of the regulatory sandbox;
• draft recommendations for innovative technologies to be integrated within the BoG, such as artificial intelligence (AI), distributed ledger technology (DLT), API management, and eID to enhance existing supervisory functions (SupTech); and
• propose legal and regulatory reforms surrounding the integration of FinTech within the Greek legal and regulatory framework.
Consultant Profile: Corporate services are required. The Consultant will be a firm or a group of firms should have expertise in financial markets legislation and regulation, with vast experience in applications of technology in finance, including expertise in various digital technologies further depicted in the Terms of Reference
The Consultant should also have proven expertise in other areas of FinTech and SupTech. In-depth knowledge of the Greek legal system and financial instruments legal environment and understanding of new legal and regulatory developments are required. The provided expertise should cover the areas defined in the description of the support to be provided.
It is expected that the Consultant’s team will consist of minimum the following Key Experts:
Key Expert 1, Legal and Regulatory Financial Markets Expert
• 10+ years of professional experience as a legal and regulatory expert with focus on legislative tools and frameworks supporting financial markets development;
• good knowledge of the Greek legal environment;
• proven experience in drafting laws and regulations;
• Master degree or equivalent in legal studies;
• proficiency in written and spoken English language;
• proficiency in written and spoken Greek language.
Key Expert 2, Pool of Technology Experts in Finance
• 5+ years of consultancy experience;
• 5+ years of experience in business transformation, digital and technology areas;
• excellent communication, analytical, report writing and presentation skills;
• proficiency in written and spoken English language.
Each of the Technology Expert in Finance shall have relevant experience in:
• 3+ years relevant FinTech experience; and/or
• 3+ years relevant Regulatory sandbox experience; and/or
• 3+ years relevant SupTech experience; and/or
• 3+ years relevant RegTech experience; and/or
• 3+ years relevant DLT experience; and/or
• 3+ years relevant IoT, AI, machine learning experience.
Key Expert 3, Data Protection Expert
• proven working experience in data protection compliance (General Data Protection Regulation (GDPR), Greek privacy laws and other relevant laws);
• legal background preferable;
• Data Protection Officer (DPO) or similar certification desirable.
Key Expert 4, Project Manager
- 7+ years of managerial experience and a track record of at least 7 successfully completed projects for financial sector EU administrations;
- Fluency in English and preferably in Greek.
The key experts may be complemented by other team members and support services to cover all tasks specified in the Terms of Reference. Consultants should note that one person could have more than one role (e.g., the Team Leader could also be a specialist) and one role could be filled by more than one person. Only CVs of the Key experts will be evaluated as part of the technical proposal.