SI will require to recognise that with increased regulatory responsibility it can no longer rely on the current structure to maintain adequate governance of business activities.
The firm will require to identify that culture is the key element in providing a dynamic, equitable and balanced environment where consumers’ interests are given the appropriate level of consideration. Improved understanding for its staff and management is needed therefore will require to implement a Compliance driven training regime that promotes essential elements such as TCF. An inherent function within this change of culture would be to adopt a ‘Compliance Champion’ in each business unit. The Compliance Champions structure would typically work in parallel with
Grandfathering a practical risk management program will require an appropriate framework to be developed in a manner that enables the business to understand its enterprise risks anticipate loss events, drive control and process excellence, minimize losses, and reduce risk. Primarily, the firms major risk categories must be defined. My suggestion would be for an appointed representative at the highest level within the firm and to adopt a culture of responsibility for ensuring these risks are clearly defined within the whole business and appropriate action taken to prevent occurrence or limit
Each business unit would be required to operate within the Issue Management process on an ongoing basis. The identification and analysis of relevant risks to the achievement of business objectives, and the assessment of the controls in place would be to mitigate those risks, forming a basis for determining how the risks should be managed. Each business unit would require performing and maintaining risk logs ongoing basis, and report on such activities as directed. The underlying factor would be comprehensively adopting an ‘outcomes based model’ for example; ‘Inspection of the risks identified in completion of gift register has been completed, judge the tolerance of inappropriate gifts on the register and impact on the firm’.
One recommendation from Nielsen, a global measurement and data analytics company, would be for Compliance to spearhead and foster an ‘organisational readiness’ ethos within the firm through evaluating the firm’s reputation with engaging with internal business lines. This could drive the firm’s strategic