Follow the soup recipe, sometimes make it better
“A sense of ethics must be innate” for anyone working in compliance, according to Anastasia Savvateeva, the Anti-Financial Crime and AML Compliance Officer for Deutsche Bank France.
In a recent interview, she mentioned she sometimes needs to explain to fledging compliance professionals the difference between compliance and ethics: “I try to explain it as simple as possible: I tell them to imagine they are cooking their favorite pumpkin soup. If they just follow the recipe — it is compliance. If they want to add something to make it better — it is ethics.”
Compliance officers (COs) ensure an organization complies with both its industry’s regulatory framework for corporate governance and its internal policies that mitigate risk, while keeping compliance costs down.
Being political savvy, effective and ethical
Reputation in the C-Suite will remain a cornerstone concern for all COs. In order to stay on top of the challenges they face, COs must meet the needs of success among the compliance community, as well as sustain the favor of the leaders they report to. Therefore, they must strive to meet the following goals:
- Recognize where they need to shore up their departments and staff
- Identify key risk and key performance indicators within their own systems
- Become problem solvers by not merely policing an organization but partner with colleagues
- Maintain transparent, solid relationships with regulators and examiners
- Remain plugged into who is in top brass in management and on the board
- Understand how the business successfully accomplishes key goals
- Stay current on emerging trends, technologies and more efficient ways to deliver
- Insist that responsibilities are clearly defined
- Identify problems early and be prepared to explain how to deliver solutions
10 challenges on the horizon
Ten priorities identified for COs came out of Thomson Reuters's annual survey on the cost of compliance and the challenges financial services firms expect to face in the year ahead:
1. Stay current on skills: Assess skills tailored to all business activities.
2. Be aware of personal liability — because 48 percent of firms expect it to increase.
3. Manage conflicts of interest by reviewing governance and control arrangements.
4. Protect data both in terms of cyber resilience, hacking theft or other loss as well as with ongoing GDPR-related issues.
5. Review personal account dealing policies regarding conflicts of interest, market integrity, personal liability and financial crime.
6. Identify relevant product target markets, including cryptocurrencies, binary options and initial coin offerings.
7. Review anti-money laundering approach on all aspects of AML/CTF, bribery, corruption, fraud prevention and sanctions requirements.
8. Anticipate a regulatory investigation and ensure plans are in place.
9. Invest in RegTech, because successful deployment would drive up efficiency and effectiveness, allowing greater focus on value-added activities.
10. Focus on complaints handling regarding needs of vulnerable customers, changes to product governance expectations and the requirement for consistently good customer outcomes.
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