We have had a busy summer here at Comsure, and I wanted to share a particular project that the whole team were involved in, and I hope offers some insight into what Comsure can do for you.

Background

COMSURE’s client was a medium-sized Jersey-based regulated business that required a full JFSC-style assessment to identify if it was meeting the JFSC’s requirements and expectations across all areas of its business and control framework.

Following the acquisition of another regulated company (tripping the firm’s size and geographical footprint) along with impressive growth in our client’s core [pre-acquisition] activities along with ever-increasing regulatory requirements, the company’s existing processes, procedures, systems and controls had not kept pace.

Consequently, the compliance function and existing systems and controls were inadequate regarding scale and scope to meet the needs of the business and regulatory requirements.

The review scope

The project scope was broad in scope and covered the following areas:

1. Governance and oversight arrangements
2. JFSC key person activities
3. Compliance Monitoring Plan
4. Risk Management Framework – both business and AML
5. Policies and Procedures – both Operating and Compliance
6. Business Continuity Planning
7. Control of Outsourced Arrangements

The Challenge

Key challenges unique to this programme were:

1. A recent acquisition of another book of business and change to principle and key persons was distracting the core stakeholders from business remediation
2. There were no existing policies and procedures in place for some processes and controls
3. The Risk Management Framework and Compliance Monitoring Plans were inadequate and out-of-date
4. Systems were out-of-date and not in line with current industry standards
5. AML/CTF, Sanctions and Anti-Bribery (collectively final crimes) controls had not kept up with regulatory change
6. Compliance resources were small, and there were significant remedial actions required

The  Solution

1. To provide our client with an efficient solution, COMSURE’s regulatory consultants initially obtained a comprehensive understanding of the firm’s business model to enable all regulatory requirements to be mapped to the company’s activities (e.g. conflicts of interest, outsourcing arrangements, AML).
2. Subsequently, COMSURE undertook an in-depth analysis of the company’s controls framework, critical systems, operational processes and the company’s suite of operational and compliance procedures.
3. The investigation involved sitting down with the major stakeholders in the business and reviewing critical processes and procedural documentation
4. COMSURE provided an opinion on the scope and adequacy of all the firm’s existing processes and controls, highlighting where some gaps or inadequacies required improvement.
5. As with all remedial action plans, COMSURE provided a clear timetable of activities and who was responsible for these to ensure that all measures were undertaken and promptly.

Outcome

1. This plan was regularly reviewed with the client to ensure the work remained on track.
2. The timetable was aggressive to deliver all the core work within the summer months. However, this work was produced and included the following:
   1. A new compliance monitoring plan and methodology bespoke to the firm’s requirements
   2. A new risk management framework and risk register, ensuring there is a direct collaboration with the company’s risk profile and regulatory licences
   3. Drafting and redrafting of policies and procedures where they were missing or inadequate
   4. Implementation of a new financial crime policy, controls and training for staff
   5. Introduction of a new Training and Competency Framework

Going forward

It is now about evolving the above outcomes (as the business embeds the new controls – fine tuning will be necessary) as well as maintaining the new controls to avoid future slippage that would result in non-compliance