MyComplianceOffice Blog

Employees at all levels of the organization make decisions that impact compliance every single day. To ensure that those decisions are wise ones, employees need to understand where they fit into the organization. If there's not a shared understanding of roles and responsibilities supported by controls and accountability there's a risk of chaotic compliance—and a chaotic culture across the firm.

Legislation has passed both Houses of the Australian Parliament to introduce the Financial Accountability Regime (FAR).

In recent months the SEC and CFTC have charged multiple Wall Street firms with widespread recordkeeping failures, handing down staggering penalties in excess of 1.5 billion dollars. Firms—including smaller ones—should only expect that the aggressive enforcement will continue.  As Sanjay Wadhwa, SEC Deputy Director of Enforcement, noted in an August 2023 release, "we know that other SEC-regulated entities have committed similar violations, and so our work to enforce industry-wide compliance continues." 

Are your books and records ready to stand up to regulatory scrutiny?

If the first stage of a pragmatic Know Your Obligations strategy is deconstructing and understanding compliance obligations to define where you need to keep your focus, the next step is mapping policies, procedures and controls to performance indicators to be able to accurately assure compliance.

Essentially, at this stage, we need to answer the question: What do we actually need to monitor?

Regulations, frameworks, policies and controls define the day-to-day of the Chief Compliance Officer (CCO) and their teams. It’s fair to say that it is an important yet often troublesome undertaking to make sense of what can often be described as monitoring spaghetti. At the same time, the teams also need to ensure they are keeping senior execs and the Front Office engaged and compliant.

So how can the CCO set regulatory priorities, identify policy and procedure gaps and understand compliance obligations?