Solid policies and procedures are the backbone of an effective compliance program, providing a framework for the consistent application of rules and requirements across the organization and third parties that the firm conducts business with.
But just having a library of policies isn't enough. The key is having policies and procedures that are clear, actionable, defensible, adhered to across the firm and consistently updated to keep pace with regulatory change. In the complex and volatile business environment that financial services firms are operating in, that goal is often easier said than done.