Thursday 8th June 2023
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Comsure operates in:the UK, Jersey, Guernsey


Compliance Support Introduction

Comsure’s compliance co-sourcing (regulated firms cannot outsource compliance – see risk warning below) support service is designed for companies that may not have sufficient internal resource to carry out day to day internal compliance tasks.

These tasks will include:-

  1. File reviews,
  2. Maintaining control registers
  3. Monitoring operational activities
  4. Assessing policy and procedures
  5. Recommending correcting actions and
  6. Writing the monthly compliance board report[s].

In undertaking these support tasks Comsure will provide appropriately skilled and insured consultants who will manage these activities for you. In all cases these services can develop and evolve.

While Compliance co-sourcing does not remove your Board’s accountability and responsibility (please see risk warning below) it does remove much of the day to day hassle involved in administering a number of Compliance processes.

“CMP+ services”
In support of the Compliance Support Comsure’s can offer a continuous monthly compliance audit by way of the “Compliance Monitoring Plan Plus”] (CMP+). The CMP+ service can be shown in the following stages.

  1. Stage 1 – Base support
  2. Stage 2 – Continuous Support

Stage 1 – Base support
A CMP audit is critical, as this is the process of establishing your Compliance status. It takes the form of Testing your internal processes and controls against a monitoring programme designed to reflect the rules that your company needs to follow.
The Comsure CMP audit will

i. Provide a clear definition of your Compliance status and what remedial action needs to be taken to address any issues raised. Comsure can run this process for you.
ii. Aim to resolve issues for you where it can, and where you need to take internal actions (for example if your governance controls are not sufficient) it will provide the guidance you need to achieve Compliance.

Stage 2 – Continuous Support

The Comsure “CMP+” offers:-

  1. Continuous business hours (with limited out of hours email support) at Director and Consultant level support.
  2. Support through face to face meetings, by telephone or by email support, whatever is best at the time.
  3. Support from advisers who have knowledge and expertise of your business and your sector.
  4. Over 50 years of collective regulatory and compliance experience

The CMP+ provides a permanent insight into such matters as:

  1. Compliance records
  2. Compliance and AML Risk Profile,
  3. Your Compliance library
  4. Regulatory Updates
  5. Regular CPD training
  6. Your own compliance to-do list

To price the above Comsure would typically wish to agree a fixed amount of time with you at a fixed monthly cost example of time used in a 10 hour annual contract.

To account for the 10 hours a month Comsure would spend up to 7 hours a month on the ground reviewing your compliance with all the applicable rules that apply to regulated firms. These reviews include:-

  • Governance & Risk Frameworks; Including
  • Board meetings
  • Committee meetings
  • Reporting between the above structures
  • Conduct of business including

i. suitability of advise
ii. investment selection
iii. client transparency

Control Framework; Including

i. front office – including client facing activities
ii. back office – including administration record keeping and compliant handling
iii. prudential – including the existence and maintenance of ANLA and appropriate insurance

Financial crime; including

i. business risk assessment and strategy
ii. client on-boarding
iii. client risk monitoring
iv. Risk and annual reviews assessments
v. MLRO and MLCO support.

In addition to the on the ground work (as shown above) – A compliance report on these matters will be written and presented to a relevant regulated firms key person (for example – CO/MLCO/MLRO) and Comsure will attend, at least once a month, a “Compliance and Risk” meeting (usually formulated as a committee).

Additional Complimentary Benefits
Included in the itemised matters above Comsure will offer on a Complimentary basis subject to an annual agreement be agreed and maintained the following:-

FREE [ITrackAML] Risk Mapping
Access to Comsure Cloud based on-line AML Risk Calculator [iTrack].
iTrack would allow regulated firms to measure the risk of each client against a number of parameters; for example client, business activity and source of funds / wealth. Regulated firms could maintain its risk assessment for all clients on iTrack and Comsure would review the inputs and the maintenance of data. ITrack would also be able to provide detailed reports based on the client data loaded (e.g. client break down based on risk, industry, investment size etc.), this would save many man hours of report writing. Please note this service is usually charged out at a minimum of £400.00 per month to non-Comsure compliance clients. (Please note this offer is subject to hosting, set up costs and users and excludes any sanction screening – additional prices available on application)

FREE unlimited CPD training
Regulated firms would have a free (1 employee) invitation to Comsure training CPD events (Priced below £80.00 per head) during the contract period. Any event over £80.00 will be offered at a discount against the advertised cost price. Additional employees would also be offered a discount.

FREE AML training
Comsure will provide a minimum amount (2.5hrs) of complimentary AML training for all employees during a single event during the annual contract period.

Going forward
Interested, in having peace of mind?


Mathew Beale – Chartered FCSI,AIFP
Managing Director – Comsure Compliance Limited
Direct Tel: +44 (0) 1534 626841
Mobile Tel: +44 (0) 7797 747 490

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