Today’s constantly evolving compliance environment presents new challenges for compliance professionals.
Whatever shape the challenge takes, financial firms can benefit from partnering with expertise they can trust. Our consultants listen and understand the specific challenges faced by financial firms and offer solutions to address the specific requirements of the challenge.
COMPLIANCE HEALTH CHECK
It pays to take a step back and make sure the basics are covered. With our Compliance Health Check service, we undertake a review process of the firm’s compliance infrastructure, covering the organization’s compliance policies, procedures, and monitoring arrangements. At the end of the review process, we provide the organization with details of areas covered, a narrative of the responses provided, and a summary of policy and procedure arrangements. This will detail any areas where weaknesses have been identified or where improvements should be made.
ELECTRONIC COMMUNICATIONS REVIEW
U.S. financial regulators have signaled increased scrutiny of electronic business communications with sweep exams and new rulemaking. We can help you meet recordkeeping requirements that affect your firm. Our team of experienced researchers can draft communications policies, conduct independent and confidential assessment of communications, and document evidence of the review.
MOCK REGULATORY INSPECTIONS AND REVIEWS
Mock regulatory examinations (mock audits) can help firms obtain the peace of mind they need in a specific area of concern. The driver for each review can be different, from recent regulatory interaction in another jurisdiction, an absence for a significant period of any regulatory interaction, changes in senior management, a “near-miss” regulatory breach or failure in key controls, or simply time for an independent review and assessment.
These reviews build on our Compliance Health Checks and involve interviews with senior management and key business representatives. They can include corroborative testing assurance around core compliance activities and higher risk themes and topics in the scope of regulatory review. Mock regulatory exams aim to assess the strength of a firm’s compliance arrangements, the level of senior management engagement with compliance risks and controls, and the prevalent culture demonstrated by the leadership of the firm and its employees.
OPERATIONAL RISK INFRASTRUCTURE DESIGN AND REVIEW
For asset management firms, operational risk remains one of the key challenges to be managed across the organization. Our consultants can review a firm’s operational risk infrastructure and help implement the right practices across the business.
In addition, we can conduct regulatory and operational due diligence on external service providers, which is increasingly important as fund boards and alternative fund managers are required to demonstrate the due diligence undertaken before and during appointment.
POST REGULATORY REVIEW REMEDIATION
After the supervisor has completed an evaluation of a firm’s activities, there can often be specific challenges that the compliance or risk teams need to meet as a result of the inspection. Our consultants have deep experience in helping firms remediate after a regulatory review. They can help establish what is needed to put things right, and help firms take the steps that are needed to ensure a specific challenge will not arise again.
REGULATORY CHANGE MANAGEMENT
The scale and velocity of regulatory change in the financial services industry over the course of recent years has put many compliance teams to the test. Our consultants can help firms better manage a specific program of new regulations, or implement new processes to help make regulatory change “business as usual.” Specific areas of focus we have helped design and implement solutions for include:
REGULATORY THEME ASSESSMENTS
We can help firms prepare for engagement with their jurisdiction’s regulatory body in a specific area of focus. These can include:
- Anti-money laundering
- Best execution
- Client money and assets
- Conflicts of interest
- Identification of research requiring payment under MiFID II
- Compliance with MiFID II research requirements when delegating portfolio management to third country managers
- Compliant research payment account arrangements
- Employee code of ethics review
- Employee trading compliance
- Governance and risk
- Marketing materials review
- Operational risk management
- Financial promotions
- MiFID II implementation health check
- Costs and charges disclosures under MiFID II
- Fitness and propriety – mock assessment
- MiFIR transaction reporting – thematic review
- Recordkeeping – transactional
- Prudential, including ICAAP