The compliance officers within financial services firms have risen to the multiple and myriad challenges of 2020, dealing not only with the global pandemic but continuing to manage their firms’ pre-existing compliance issues.
Now more than ever, corporate risk and compliance officers have been and need to remain at the forefront of preparing their firms for any and all eventualities.
To shed further light on this, Thomson Reuters Regulatory Intelligence has published a new report, 10 Things Compliance Officers Need to Consider in 2021, that discusses these challenges and how corporate compliance officers can best prepare for them.
One element that the impact of the global pandemic has made crystal clear is the importance of culture in a firm. An effective risk-aware culture could perhaps be the most valuable asset a firm can develop and maintain — such a culture will enable the firm and its employees to better weather uncertainty and change.
You can download a copy of 10 Things Compliance Officers Need to Consider in 2021, here, and watch author Susannah Hammond, senior regulatory intelligence expert at Thomson Reuters Regulatory Intelligence, discuss the key themes of the report here.
The crisis has shown that firms can change and adapt with speed when necessary. Thus, it is essential that firms take the time now to assess what went well and what did not to better adapt their business continuity plans that were made at the outset of the pandemic. Being able to act with speed is commendable, of course, but that does not change the rules, requirements, and regulatory expectations that all firms still face. Indeed, firms still need to be able to evidence both compliance and the required good customer outcomes. Regulators were generally acknowledged as having responded well to the pandemic, and ideally financial firms should be able to say the same.
Regulators have already committed to post-pandemic reviews; and while firms are likely to want to do the same, they should continue their immediate focus on recordkeeping. Specifically, meticulous care must be given to making sure that all changes to policies, procedures, and oversight have been recorded, and decision-making has been comprehensively documented. Without detailed recordkeeping and retention, it will be almost impossible to show that a firm has followed the correct policies and procedures and has remained compliant during the pandemic.
As experienced corporate compliance officers know, the only true test of a policy comes once it has been utilized in the real world. Detailed jurisdiction-specific policies and procedures may look great on paper, but until they have been tested in the often-controlled chaos of an unexpected adverse event, there is no way to know whether or not they work as intended. Any post-pandemic compliance review should be used to refine and update policies and procedures to reflect any new ways of working and to initiate a new round of training and awareness for the entire firm.
As ever, compliance officers will need to be fully engaged to give their firms the best chance of a trouble-free 2021. There are a range of consistent issues and challenges that all compliance officers — no matter the size, jurisdiction, or sector of their firm — will need to consider.
You can also listen to Thomson Reuters Regulatory Intelligence’s new podcast, “Compliance Clarified”, available on Apple, Spotify, and Google.
You can find more information on Thomson Reuters Regulatory Intelligence here.