ACL regularly conduct reviews of the compliance function. Areas typically covered during an external independent review of the firms’ compliance department include: -
- Examination of the departments’ own procedures, systems and controls (for example: the provision of management information to the business; the extent of its responsibilities for monitoring and advising the business on regulatory [and operational] risk; dealing with non-compliance; the financial promotions approval process; and; the coverage of detailed monitoring programmes).
- Service standards. Does the department have published service standards against which its progress and contribution to the business can be measured by the Board/executive management team? This is particularly significant where the department has a Compliance Plan (for details of what this document should contain, visit the Services area of ACL’s website).
- Relationship management. How do other departments perceive the Compliance departments’ contribution to the business? It is not unusual for business relationships to become strained over time. What can be done to mitigate this?
- Is over-reliance being placed on the words of relatively junior members of staff from your regulator?
Unlike an audit carried out by the firms’ own Internal Audit function, an external independent review conducted by an experienced regulatory compliance consultant can also consider the veracity of the regulatory compliance guidance provided by the department to the business (for example, the ‘compliance manual’; its procedures for dealing with anti-money laundering and the financing of terrorism, and; the periodic guidance provided to the business in relation to rule changes affecting the business).
To obtain more information about this service, contact us.