Today’s constantly evolving compliance environment can sometimes create a need for something more. More understanding. More ability. More agility.
Most compliance professionals know what this moment of realization feels like. A regulator has demanded an exam. Or a package of fresh rules has appeared in an inbox. Or an innovative business line is being added in a new jurisdiction. Or another significant – often unanticipated – challenge has appeared.
Whatever shape the challenge takes, the compliance team knows it needs to partner with expertise it can trust. Cordium’s experts will listen and understand the specific challenges being faced. Every project is specific to the needs of the organization.
COMPLIANCE HEALTH CHECK
Sometimes, it pays to take a step back and make sure the basics are covered. With the Compliance Health Check service, Cordium undertakes 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, Cordium will 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.
REGULATORY THEME ASSESSMENTS
Cordium 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 and infrastructure development
- Client money and assets
- Conduct and culture
- Conflicts of interest
- Employee code of ethics review
- Employee trading compliance
- Governance and risk
- Marketing materials review
- Prudential, including ICAAP
- Trade allocation review
MOCK REGULATORY INSPECTIONS
Regulatory Inspections (Mock Audits) help firms obtain the peace of mind they need in a specific area of concern. The driver for each review can be very different. 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.
Cordium can also help firms prevent Skilled Person Reviews – conducted by the UK regulators and in other jurisdictions – by working with them to improve policies, procedures and practices. Cordium will undertake assessment reviews to identify weaknesses that could potentially lead to skilled person action and provide remediation proposals. In addition, we will also assist with remediation after a skilled person review undertaken by another firm at the regulator’s request.
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. Cordium’s expert 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 at the moment for firms include:
- MiFID II
- Regulatory filing and reporting
OPERATIONAL RISK INFRASTRUCTURE DESIGN AND REVIEW
For asset management firms, operational risk remains one of the key challenges to be managed across the organization. Cordium’s experts will review the firm’s operational risk infrastructure and help implement the right practices across the business.
As well, Cordium is able to conduct regulatory and operational due diligence on external service providers. Outsourced due diligence will become increasingly important with the implementation of AIFMD 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. Cordium’s team of 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.