Project Description
Running a regulated company is a complex business. Inevitably, sometimes things don’t go to plan.
Uncomfortable though it is to admit it, in the real world, try as we might, compliance systems failures and regulatory oversights are an inevitable fact of life. The important thing is to :-
- Recognize them at the earliest possible opportunity
- Remediate the problem.
- Revise your systems to avoid them in future.
Remediation – What it means and how we can help.
In compliance terms we sometimes think of ‘remediation’ as a set of requirements imposed on us by the regulator.
However, in an ideal world the need to remediate would first be identified by the company itself, either through routine monitoring cycles or through an independent external review commissioned by senior management to undertake a health check of the company’s internal compliance systems. (The Rowany independent compliance system review service can assist with this.) Thus, any issues can be identified and resolved without the need for regulatory intervention.
Of course, specific remediation actions will vary depending on the nature of deficiency but two parallel responses are usually required.
Specific response
- Identification of deficiency whether through an internal or external review or by the IOMFSA
- Consider how to rectify the deficiency – is additional training required, a separate project rectification team or revision to processes and procedures, or a combination?
- Agree time scale for remediation – where required ensure that IOMFSA are provided with the necessary notifications
- Undertake the remedial action required
- Report on progress – including, where appropriate, to the IOMFSA
Update the business, technological and client risk assessments as appropriate
System response
- Examine the existing systems to understand how deficiency arose
- Redesign the system of compliance or procedures to address the identified deficiency
- Document the methodology adopted and outcomes
Report to management ensuring that where material changes to the systems and procedures are proposed that approval of the board is documented – where appropriate notify the IOMFSA
Test the revised systems and procedures, provide training and update procedures
Implement the revised system
Whether your deficiency is a simple staff training related oversight or a more complex deep rooted CDD issue, we will provide you with unbiased, commercial non judgemental advice on how to get things back on track.
For further information please contact Francesca on 200740 or email francesca@rowany.im
