A Master’s Thesis that highlighted the importance of timely submission of the Annual Report
In May 2023, Creditinfo Eesti announced a prize fund to recognize students who have addressed research questions in the fields of money laundering and sanctions in their research. In cooperation with the COBALT law firm and the representatives of the State Money Laundering Bureau, the evaluation committee chose Victoria Helenurme, a master’s student from the University of Tartu, as the winner for her master’s thesis on the topic “Prediction of deletion from the business register due to non-submission of the annual financial report using the example of Estonian companies”.
Victoria Helenurm is from Tallinn and graduated cum laude from the University of Tartu, majoring in Marketing & Financial Management. Today, she works as a financial controller in a company offering energy-saving indoor climate and renewable energy solutions and sees her future in business.
We had an interview with her on the journey of her thesis topic:
The topic of your thesis was “Prediction of deletion from the business register due to non-submission of the annual financial report using the example of Estonian companies” – how did you arrive at this topic?
At the beginning of the summer of 2022, discussions began with people who eventually became my thesis supervisors. My main desire was to write a paper on a current topic in society. This year, the Estonian state penalties for not submitting the annual report became harsher, and in cooperation with my supervisors, we saw that there is a public interest in this area of research and also sufficient data for research.
Why was this topic worth researching?
If, as a person, we take a loan, for example, we are understanding the obligations that come with taking a loan. For me, founding a company or being on its board is a somewhat similar responsibility – as a manager, we have assumed the responsibility, among other things, to report on the progress of our company’s business to the public.
Unfortunately, while we are mostly exemplary in servicing loans, tens of thousands of Estonian companies fail to submit their annual reports on time.
I cannot say whether this difference is due to, among other things, the fact that the penalties for not submitting the annual report have been relatively lenient. But it is certainly worthwhile for us to become more aware that such behavior is problematic.
After all the state of our countries businesses is based largely according to the data of the Business Register. If we have thousands of active companies that do not fulfill their reporting obligations, the financial forecasts, risk analyses, business decisions, etc. of the state, lenders and other parties will suffer in its quality.
The submission deadline (6 months after the end of the financial year) is a very lenient deadline. The business landscape is more and more unpredictable, so the knowledge of the previous year’s business results that arrives half a year later is already outdated. As is typical of our e-government, we would expect that at least certain types of companies could be assigned a much earlier submission obligation to help update our economic data.
What facts became clearer as part of the research?
In my research, I tried to find an answer to the question of whether the deregistration of a company can be predicted purely by looking at how the company’s management has cared about the obligation to submit an annual report in its previous business life.
The Estonian financial world is very much a believer in financial ratios when assessing the business health of a company. I tried to see if it is possible to convincingly assess the business risk of deleting the company by completely setting aside the financial statement.
The studied dataset also proved this – a significantly more accurate forecasting method than financial ratios (prediction accuracy approx. 63%) was the observation of the past behavior of board members (prediction accuracy almost 82%). It can be said that if there is a member of the board of the company who has either delayed or failed to submit the financial year report in previous companies, it is a very clear business risk, which indicates the risk of deletion of the company in question.
How could this research topic be continued?
Although I myself rather do not plan to continue my studies in a doctoral program, I definitely see possibilities for expanding this research topic. The obtained research results could certainly be compared with our neighboring countries – to assess whether in Latvia, Lithuania, Finland, etc. there are similar relationships between corporate delisting and board members’ past due diligence.
Another immediate opportunity for investigation is provided by the amendments to the law that entered into force this year, which toughened the penalties for failure to submit an annual report, among other things. Repeating this research in 5+ years would give an idea of whether business behavior has improved in terms of reporting obligations.
We were very pleased with Victoria’s research, as her research clearly connected with the general theme of our competition – the data of the Business Register and national registers in general are the main factors when applying the KYC principle. Financial data from the company that is not submitted on time or is completely missing, is a clear danger signal when investigating the background of your business partner.
When it comes to risk management – both when creating a customer relationship and during the existence of a customer relationship, up-to-date data from the business register is very necessary. Does the company actually operate; whether the data there (especially the field of activity and financial data) are correct (especially when it comes to the application of enhanced due diligence measures). The given data helps to understand the customer’s activity profile.
If the client does not submit annual reports, it is clear that it may be a riskier client, and this should be taken into account when establishing or monitoring a business relationship in order to mitigate the risk.
Urmas Pai – KYC&Fraud Global Product Manager, Head of the evaluation committee
Creditinfo Estonia
The Know Your Customer (KYC) world and Creditinfo’s role in it.
The acronym KYC stands for three very simple and understandable words – Know Your Customer. But the meaning of the processes and expectations behind those three letters are most often not so simple and straightforward, as whoever must deal with this today already well-known acronym, knows that the world and the industry behind this magical acronym, is already vast and growing every day.
KYC in very essence means that you must have understanding and information of the background of your customer. Often this information is divided into three basic categories:
- Identification of the persons connected or operating behalf the customer.
- The field of activity or daily business including the understanding of the origin of the customers funds.
- The understanding if customer possesses certain risks while having any business relationships with him.
Mainly this sort of detective work is required in the purpose of mitigation the risks in anti-money-laundering/fight against terrorism financing (AML/CTF) but it is also relevant in the process of imposing international sanctions as sanctioned persons are interested that their business interest would remain undiscovered.
Even companies that are not subject to AML regulation need to ensure that they stay out of trouble caused by risks that are risen because of partners or clients with fraudulent, criminal, or sanctioned background, as this may result with loss of revenues/funds, bad business reputation or fines by authorities.
So therefore, it is essential for market entities to trust their business affiliates and therefore they need to verify that everything is OK with their customers and threat of the damage caused by realization of different risks, is minimized.
What is happening in Europe to strike this conversation now?
One very practical side for knowing your customer is to be sure that you’re not violating any sanctioning regime in force. Sanctions and sanctioning regimes may not be familiar to all of us who we just are involved our day-to-day business, but this obligation is something we all must know and follow. International sanctions are seen as sort of political means for influencing certain group of entities, jurisdictions, or organizations to behave in line to accordance with the international human rights, rules of law and territorial integrity. Sanctions are imposed in a way that all private and legal entities are obliged to fulfill them, authorities who are imposing them are usually international organizations (EU, UN) or state governments.
As Russia launched massive war campaign in Ukraine in February 2022 and has performed several actions against Ukraine’s territorial integrity already from year 2014 this kind of behavior has naturally found a reflection from EU by imposing sanctions. As from 2014 there was already two regimes in force (regulations EU No 269/2014 and No 833/2014) it was easy on 2022 to EU to add several sanctioning updates (altogether by 8 packets) against Russia (and Belarus).
As the conflict remains in Ukraine and also as there are several war crimes discovered performed by Russian troops during the occupation of Ukraine, we can be more than certain that EU will impose more updates to Russian sanctioning regimes. This only intensifies the need for market entities to have a clear understanding on what are the situation regarding the restrictive measures in force and where to find that information.
How is CREDITINFO playing a role in this?
Mitigating the risks is always the question of having updated and trustworthy information that person must have for making decisions and enforcing correct procedures. Regarding risk mitigation and imposing enforced sanctioning regimes clients often face themselves in front of different questions –
- What exactly do they have to do?
- How do they do it?
- Where can they find help and trustful partner for this?
- Are the solutions for doing it comfortable and simple to use?
- How expensive is it?
Providing both, the trustworthy information from respectful sources and the solution for being compliant in the regards to that obligation (by using Creditinfo-offered solution) is one of the ways of building up successful client relationship in KYC sector (obligations in KYC area may differ depending on the AML/TFC and imposing sanctions viewpoint). KYC procedures regarding sanctions can be divided into two different service blocks:
- Identifying the persons behind and connected to legal entity.
- Easy to use, reliable screening solution for determining whether there are imposed sanctions or not.
It is important to have flexible products in place for meeting the needs for most of the market entities as clients tend to prefer to order all the solutions from one place. For example, clients may have the need only for determining certain persons connected with legal entities (like UBO’s), other clients may only need data sources for setting up internal screening procedures for their inter-company use, while others are just willing to outsource everything (analysis, data and screening).
Lastly, instead of being in the last mile lets be the first! As already mentioned, there are different market entities who are operating in KYC business, and they are all seeking for cost efficient and trusted data sources for providing best data quality with best price to their customers. Creditinfo Group’s presence in several different countries, with the direct access to local state registry information or other base data source in those countries therefore makes us one of the trusted partners for well-known global companies.
KYC products are in process of continuous development and as the needs for our clients change, we need to align our services accordingly. If there are ideas, proposals, or questions, please feel free to reach me via email – urmas.pai@creditinfo.com
Urmas Pai
KYC & Fraud Global Product Manager
