Specialised Solutions for Authorised Deposit-Taking Institutions’ Compliance

We offer a comprehensive set of risk and compliance solutions tailored to a variety of authorised deposit-taking institutions' compliance obligations. We can help you comply with Australian Prudential Regulation Authority (APRA) standards in a commercially oriented and goal-focused manner, providing a tailored approach to authorised deposit-taking institutions' (ADIs') compliance management with regard to your specific circumstances, including:

• Your commercial objectives
• Your deposit-taking solutions and other products 
• Your business size
• Your technology and human resources
• Your risk appetite
• Your governance structure
• Your client demographics
• Australian APRA standards and ADIs' licensing requirements, including key aspects such as outsourced providers' monitoring, compliance training, risk management, audit, and assurance.
• If necessary, ADIs' compliance obligations in other countries and states where you operate, under their respective national and state laws.
• Any related compliance obligations, including, but not limited to, authorised deposit-taking institutions' obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, fair trading laws, and more.
• ADIs' compliance assurance obligations, including internal control design and testing, implementation of compliance calendars, management plans, compliance assurance programs and other second and third-line compliance requirements.
• Specific operational compliance requirements for authorised deposit-taking institutions, including but not limited to:
  • Client due diligence and onboarding
  • Surveillance and monitoring
  • Recordkeeping
  • Conflict of interest management
  • Regulatory technology (RegTech) integration
  • Internal reporting
  • External reporting
  • Transaction execution
  • Regulatory Filings

 

What Jurisdictions Do Our Compliance Solutions Cover?

Our compliance solutions extend across major financial markets and cover APRA standards and ADIs' licensing requirements in the following jurisdictions:

• Deposit-taking Institutions Australia: This page is dedicated to Australian Authorised Deposit-taking Institutions Compliance Solutions. Australian non-bank deposit takers that accept customer deposits are classified as Authorised Deposit-taking Institutions (ADIs) and regulated by the Australian Prudential Regulation Authority (APRA) under the Banking Act 1959. ADIs are subject to APRA ADI regulation and APRA Guidelines, including prudential standards and ensuring the security of customer deposits.
• Other jurisdictions: Beyond Australia, we also offer risk and compliance solutions for ADIs or their equivalents in the following jurisdictions:

• United States: Where ADIs are classified as Savings and Loan Associations and regulated by the Office of the Comptroller of the Currency (OCC) under the Home Owners' Loan Act. These institutions should follow strict guidelines to ensure the safety and soundness of their operations. For more information about our compliance solutions for US Finance Companies, visit our Savings and Loan Associations compliance solutions page.
• United Kingdom: Where ADIs are classified as Building Societies and regulated under the Building Societies Act 1986. They should also comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 to ensure transparency and prevent financial crimes. For more information about our compliance solutions for UK Finance Companies, visit our Building Societies compliance solutions page.
• Singapore: Where ADIs are classified as Finance Companies and regulated by the Monetary Authority of Singapore (MAS) under the Finance Companies Act and applicable MAS regulations. For more information about our compliance solutions for Singapore Finance Companies and MAS Finance Company regulation, visit our Finance Companies compliance solutions page.
• New Zealand: Where ADIs are classified as Non-Bank Deposit Takers (NBDTs) and regulated by the Reserve Bank of New Zealand (RBNZ) under the Deposit Takers Act 2023 and some provisions of the Non-bank Deposit Takers Act 2013 and Banking (Prudential Supervision) Act 1989. For more information about our compliance solutions for New Zealand Finance Companies, visit our NBDTs' compliance solutions page.
• Cayman Islands: Where ADIs are classified as Class B or Class C Banks and regulated by the Cayman Islands Monetary Authority (CIMA) under the Banks and Trust Companies Law. These entities should comply with stringent financial regulations to maintain their licences and ensure transparency.
• Bermuda: Where ADIs are regulated under the Banks and Deposit Companies Act 1999 by the Bermuda Monetary Authority (BMA). These institutions should adhere to comprehensive prudential standards to safeguard depositors' interests.
• British Virgin Islands (BVI): Where ADIs are regulated under the Banks and Trust Companies Act 1990 by the British Virgin Islands Financial Services Commission (BVI FSC). These entities are required to follow strict compliance and reporting standards to operate.
• Isle of Man: Where ADIs are regulated under the Financial Services Act 2008 by the Isle of Man Financial Services Authority (IOMFSA). These institutions should ensure robust compliance with local financial regulations to protect depositors and maintain operational integrity.

 

What types of ADIs do we offer services?

Our ADIs' compliance solutions cover the following types of financial institutions:

• Restricted ADIs: Businesses granted a Restricted ADI Licence, allowing them to conduct limited banking activities for up to two years while transitioning to a full ADI licence under APRA’s regulatory requirements.
• Credit Unions: Member-owned financial cooperatives offering savings and loan products to their members while operating under the ADI framework, maintaining financial stability and consumer trust.
• Building Societies: Businesses providing members with banking and savings products, operating as ADIs and adhering to regulatory compliance and transparency requirements.
• Mutual Banks: Member-owned ADIs that have transitioned from credit unions or building societies, offering a full range of banking products while complying with prudential standards.
• Foreign Bank Branches: Businesses operating in Australia under a foreign ADI licence, providing wholesale banking services while restricted from accepting retail deposits below $250,000.
• Banks: Businesses licensed to provide deposit-taking and financial services under APRA's prudential oversight, ensuring compliance with capital, liquidity, and governance requirements. Includes major banks, regional banks, foreign subsidiary banks, and digital banks.
• Related Financial Activities: Businesses involved in lending and investment operations following the receipt of investor deposits, ensuring compliance with regulations around protected deposits.

 

ADIs’ Compliance Advisory

Our focus areas include:

• Detailed Compliance Advice: Covering ADIs' compliance management issues across the first, second, and third lines, as well as matters related to effective compliance with market conduct and consumer protection-related obligations and ADIs' licensing requirements.
• Banking Relationships Advice: On risk and compliance issues related to managing and expanding relationships with banks, liquidity providers, and other financial institutions to help you meet their risk appetite requirements, anti-money laundering and counter-terrorist financing requirements, fraud prevention and recall volume expectations, and other compliance-related and operational standards.
• Operational AML Advice: Advising support, onboarding, KYC, operating and other teams on the day-to-day onboarding and support queue management, effective AML/CFT resource allocations, and operational improvements, helping you maintain the overall customer experience and efficiency while remaining compliant with authorised deposit-taking institutions' AML/CFT requirements.
• Operational Compliance Advice: Advising compliance, management, technology, and support teams on the day-to-day compliance with APRA standards, focusing on internal processes and critical internal controls for effective ADIs' compliance management.
• Risk Management Advice: Covering risk rating and methodologies, risk assessments, management, and mitigation for various risk types faced by authorised deposit-taking institutions, including regulatory, ML/TF, fraud, data protection, and operational risks. We help you safeguard against potential compliance breaches and comply with risk management obligations under ADIs' licensing requirements and other applicable laws and regulations.
• Compliance Framework Advice: To help you create or enhance your compliance management framework, identify gaps and areas of improvement, meet the authorised deposit-taking institutions' compliance obligations effectively, improve internal governance and reporting, and optimise them for market expansion and growth.
• ADIs' Licensing Advice: We can guide you through the licensing process, help you apply regulations to your specific circumstances and business environment, and meet ADIs' licensing requirements to become licensed or maintain it.
• Peer Benchmarking and Best Practices: We can help you benchmark your compliance practices against peers and applicable regulatory compliance guidance, identify areas for improvement and adopt best practices for enhanced compliance.
• Government Agencies Liaison Advice: We provide strategic guidance to senior management and compliance teams on maintaining and managing relationships with external bodies, including regulators, AML/CTF supervisors and law enforcement agencies, focusing on long-term compliance strategies and proactive engagement.
• Specific ADIs' Compliance Issues: We can help you resolve specific risk or compliance issues related to APRA standards and compliance obligations, including but not limited to external audits and reviews, reporting, oversight, difficult clients or transactions, expansion challenges, compliance management issues, process optimisation, regulatory challenges you may encounter and more.
• Further information: You can visit our Regulatory Compliance Consulting Solutions page for a comprehensive list of advisory services we offer to ADIs and other licensed financial institutions, financial services providers, and regulated businesses.

 

 

Reporting and Regulatory Liaison Solutions for ADIs’ Compliance Management

• Regulator Liaison Management: Providing operational guidance to senior management and compliance teams on managing relationships with regulators, AML/CFT supervisors, police bodies, privacy commissioners, and other government entities. This includes handling requests for information, responding to ad-hoc regulatory inquiries, managing findings from audits and investigations, managing compliance with reporting obligations for authorised deposit-taking institutions and more.
• Board and Committee Reporting: Facilitating structured reporting workflows for various committees and board delegates, including risk, compliance, and audit committees, focusing on your current compliance status, deviations from your risk appetite, changes in risk ratings and any operational compliance updates to ensure that governance structures are well-informed and aligned with compliance management practices.
• Compliance Performance Metrics: Developing and presenting comprehensive compliance performance metrics to the board or relevant committees, offering insights into your compliance effectiveness and identifying points for improvement in key compliance areas, including compliance training, fraud prevention, compliance monitoring, risk rating and assessment, controls effectiveness, adherence to your compliance calendar, regulatory technology (RegTech) performance, and more.
• Internal Audit Reporting: We can help you increase the effectiveness of the internal audit to make its findings reflect your actual performance against the authorised deposit-taking institutions' compliance obligations. This includes developing tailored methodologies for the auditors, preparing the necessary audit evidence and reviewing audit results. The goal is to ensure that audit procedures and outcomes directly contribute to maintaining and enhancing your compliance status and internal controls' effectiveness.
• AML/CFT Reporting Compliance:  We help with the implementation of effective AML/CFT reporting processes, aligning with specific anti-money laundering regulations for internal oversight and prompt escalation of critical AML issues within your business to help the management receive a clear overview of your AML/CFT compliance status.
• Transactional Reporting: Implementing effective transactional reporting procedures to help with ADIs' compliance management of reporting obligations under various laws and regulations, including submitting SAR, SMR, STR, PTR, TTR, specific reportable matters under the ADIs' licensing requirements and other externally reportable transactions and activities.
• Internal Quality Assurance Reporting: While second-line control testing is crucial for complying with APRA standards, including ADIs' licensing requirements, first-line quality assurance results are equally important for effective risk and compliance management. We help organise effective reporting lines, tailor reporting content to your specific circumstances, products, and team size, and establish a structured approach to responding to reporting outcomes.

 

 

Comprehensive Compliance Management Solution for ADIs

Our compliance management services include, but are not limited to, the following:

• ADIs' Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable ADIs' licensing requirements, laws, regulations, industry codes, and regulatory guidance.
• Second-Line Compliance Management: We offer a full range of second-line compliance assurance solutions, including internal controls testing for operational, compliance, marketing, legal and other risks, as well as managing issue closure control testing and more.
• Supporting the Board in Strategic Compliance Management: Advising on the necessary compliance resourcing, budget, tools, role structuring, and compliance functions' structure to support your specific business objectives within your risk appetite and risk management framework.
• Compliance Project Management: Effectively coordinating between senior management, committees, legal advisers, risk and compliance functions, outsourced providers, and different departments, including product development, technology, customer support, operations, assurance, marketing, and others, to help you successfully implement compliance projects across the business.
• Customised Governance Solutions: Tailoring governance frameworks and mechanisms to fit your specific governance structure and effectively comply with APRA standards and other applicable obligations. Whether your business is locally oriented, a start-up, undergoing expansion, part of a multinational group, has a listed parent company or is undergoing restructuring, we tailor the oversight of ADIs' compliance management to your business case.
• Stakeholder Management and Reporting: Reporting to the board, committees, shareholders, regulators and other stakeholders. Providing management and the board with comprehensive compliance reports that cover your compliance with authorised deposit-taking institutions' compliance obligations, regulatory development summary, compliance-related data and statistics, internal controls testing outcomes and more. Also covering the status of your specific compliance-related projects and compliance goals, relevant compliance KPIs, and more.
• Compliance Calendar Implementation: We design and implement compliance management programs and calendars, covering such areas of authorised deposit-taking institutions' compliance obligations as policy and key document reviews, control testing, risk assessment and reviews, vendor reviewers, user system access reviews, assurance activities and more.
• Managing Customer Onboarding and Due Diligence: Implementing commercially oriented and compliant processes for KYC information collecting, Know Your Business (KYB), ML/TF risk assessment, PEP and Sanctions screening, CDD and EDD, especially for higher ML/TF risk clients, to help you comply with AML/CFT compliance obligations for authorised deposit-taking institutions.
• AML Transaction Monitoring and Reporting: Developing and implementing a set of business-specific ML/TF alerts and red flags to detect and report suspicious transactions to comply with the ADIs' AML requirements without making AML/CFT compliance a hindrance to business.
• Information Requests and AML/KYC Data Sharing: Handling information requests from law enforcement agencies, AML/CTF supervisors, and other relevant AML/CTF designated entities, such as your banking partners and other essential service providers (liquidity providers, finance providers, etc.), ensuring that you are fully supported in all AML/CTF compliance-related communications.
• Business Expansion Support: Providing support for your business expansion objectives, recognising and assessing new risks, developing and implementing controls and mitigations for them, as well as addressing new compliance obligations and putting in place practical tools and systems to manage them.
• ADIs' Operational Compliance: Including but not limited to:
  • On-the-Ground Compliance: Conducting compliance management meetings, organising routine and ad hoc compliance reporting, overseeing mitigations and controls testing, leading adjustments and enhancements to your internal controls and protocols when required.
  • Compliance Process and Operations Building: Developing effective and compliant procedures and processes to implement your policies, support your operations across different teams and mitigate operational, regulatory and other risks.
  • Outsourced Provider Performance Monitoring: Setting up initial due diligence and ongoing review frameworks for your outsourced providers to help you meet the required service standards for outsourcing under various authorised deposit-taking institutions' compliance obligations, including ADIs' licensing requirements.
  • Incident Management and Reporting: We can help you set up effective processes for incident reporting, escalations, and management at different levels of your business.

 

ADIs’ Compliance Assurance 

Our services include:

• Compliance Assurance Programs:  We can design and implement your compliance assurance program to maintain enhanced oversight of your compliance with both APRA standards and your internal compliance and risk appetite thresholds.
• Organisation-Wide Risk Assessments: Helping you focus on the specific risks faced by your business, considering its size, products, client types, jurisdictions of operation, delivery channels, financial institutions you interact with, available technology, and other tools. This includes assessing available mitigations, controls, their effectiveness, residual risk ratings, and the plan to move forward.
• Internal Controls Design: We can develop internal controls for various risk types, including regulatory, fraud, operational, strategic, financial, and other risks. Please visit our Internal Controls Design page for more information. 
• Assurance Testing: We conduct assurance testing to verify that the business complies with its policies, procedures, and authorised deposit-taking institutions' compliance obligations, including ADIs' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable APRA standards. This process includes a compliance controls testing report and, if necessary, a gap analysis.
• Compliance Quality Assurance: We go beyond merely meeting regulatory requirements. We focus on evaluating and enhancing your risk and compliance management processes to ensure they align with your current and future goals, business model, your risk analysis, your current client inflow, and more. We also suggest which compliance processes you can use to meet your goals. Here is an example of this service in the AML/CFT area.
• Assurance Reporting: Compiling testing findings and issuing comprehensive compliance assurance reports, which include:

• Identification of any deficiencies or control weaknesses, with clear explanations and potential root cause analysis.
• Recommendations for corrective actions to address identified issues and enhance compliance effectiveness.
• Evaluation of the overall effectiveness of your internal controls and regulatory compliance monitoring program against your desired assurance level.

• Regulatory Inspection Readiness: We can help your business prepare for external audits and regulatory inspections, reducing the risk of adverse findings related to authorised deposit-taking institutions' compliance obligations. This includes conducting mock inspections to identify gaps, reviewing documentation and record-keeping practices to ensure all relevant materials are well-organised and readily accessible, and training staff on their roles in the inspection process. We assist in identifying any missing information and weak points, provide interview preparation, and more to ensure readiness for auditor or regulator review.
• Further information: You can visit our Compliance Assurance Solutions page for more information on our third-line compliance assurance review solutions.

 

Compliance Remediation Solutions

Our focus areas include:

• Compliance Remediation Advice: Assisting authorised deposit-taking institutions in effectively addressing and rectifying compliance issues, from minor breaches to significant regulatory challenges, including warnings and action plans.
• Remediation Plan Development: Following the independent review, we assist in analysing the findings to identify necessary remedial actions. We then support authorised deposit-taking institutions in devising a detailed plan outlining these actions for submission to your regulator or an AML/CFT supervisor, ensuring the plan is both actionable and compliant with regulatory expectations.
• Remediation Plan Commitment: We help authorised deposit-taking institutions complete their remediation plans and prevent non-compliance recurrence.
• Executive Attestation Support: Our services include assisting senior executives in preparing the required attestations to your regulator. This involves confirming that all necessary remedial actions have been undertaken and adequate compliance measures are in place, supported by comprehensive documentation and evidence. This option covers assistance with the removal of any licensing restrictions.
• Further Information: For more information, you can visit our Compliance Remediation Solutions page.

 

 

Internal Controls Testing and ADIs’ Compliance Management

When it comes to reality versus a nice policy or procedure with nothing else to show for it, it’s often a case where a policy says A, but reality says B. One might ask, why didn’t we test our internal controls before? Or, why didn’t we do it properly? There’s nothing worse than faking compliance instead of actually doing it.

Our second line of compliance defence solutions covers the development, testing, and enhancement of a wide range of controls to ensure compliance with various laws and regulations governing authorised deposit-taking institutions' compliance obligations.

We go beyond merely quoting APRA standards or a selection of licensing requirements, then adding Excel sheets painted in different colours as a supposed source of truth with nothing to show for it.

• We test them.
• We link them to your risk appetite and core risk management documentation.
• We provide relevant suggestions and analysis tailored to your business.

Some of our focus areas for testing the authorised deposit-taking institutions' compliance requirements include:

 

Regulatory Compliance and Licensing Controls

• Financial Services Compliance Management: ADIs should ensure that all financial services comply with relevant laws, regulations, and standards. This includes having robust compliance management systems to adhere to various regulations governing banking and deposit-taking activities.
• Liquidity Management: Deposit-taking businesses should maintain sufficient liquidity to meet operational needs and withdrawal demands, aligning with APRA's standards.
• Capital Adequacy: ADIs are required to maintain adequate capital to cover operational and credit risks, particularly under frameworks like Solvency II in the EU and APRA's guidelines.
• Financial Risk Assessment: ADIs are expected to regularly perform comprehensive financial risk assessments to identify potential threats to their financial stability. This includes evaluating market risk, credit risk, liquidity risk, and operational risk, and implementing appropriate mitigation strategies.
• Financial System Stability: ADIs should develop and maintain internal controls that contribute to their own stability, ensuring they are resilient against systemic risks and can continue operations effectively.
• Financial Auditing: Depending on the compliance requirements, deposit takers are either expected or should validate their financial health through engaging qualified auditors who should conduct regular financial audits.
• Compliance Audits: ADIs are expected to conduct regular compliance audits to assess adherence to regulatory standards and internal policies. Sometimes these audits are compulsory like the periodic external AML/CTF compliance audit, and sometimes they are an expectation like the 3rd line audits and reviews under their CAP programs.
• Cross-Border Application of Regulations: ADIs should adhere to international banking regulations and standards when offering services in multiple jurisdictions.
• Prudential Supervision Compliance: ADIs are expected to comply with prudential supervision requirements set by regulatory bodies.

Operational Oversight Controls

• Outsourcing Oversight: Deposit-taking businesses should control third-party services for technology, payment processing, or customer support to comply with regulatory standards such as GDPR in the EU and the Privacy Act in Australia.
• Risk Management: Entities that comply with online bank regulations should identify and mitigate financial, operational, and cybersecurity risks, aligning with guidelines from regulatory bodies like the OCC in the US and the PRA in the UK.
• Governance Arrangements: Deposit takers should establish effective management structures and decision-making processes to comply with governance standards set by authorities like APRA and the ECB.
• Senior Management Accountability: Senior managers in ADIs should be assigned specific responsibilities to ensure accountability for compliance and risk management practices.
• Operational Resilience: Deposit-taking businesses are expected to ensure the continuity of banking operations, especially in the digital banking context, adhering to resilience standards set by regulatory bodies across different regions.
• Technology Risk Management: ADIs should manage the risks associated with digital banking platforms, including data security, system reliability, and protection against cyber threats, in line with regulations from entities like MAS or the FCA.
• Cybersecurity Governance: ADIs should establish a cybersecurity governance framework to oversee cybersecurity risks and ensure alignment with regulatory expectations.
• Incident Response Plan: Deposit-taking institutions are expected to maintain a detailed incident response plan to address potential cybersecurity breaches promptly and effectively.

Market Integrity and Transparency Controls

• Market Conduct Standards: ADIs should ensure fair and transparent banking practices, particularly in customer interactions, product offerings, and advertising.
• Fair Dealing Principles: Deposit-taking businesses should guarantee fair treatment of customers, offering transparent terms and conditions, especially for loan products and deposit services.
• Conduct and Disclosure Standards: ADIs are expected to maintain high standards of conduct and ensure clear, effective disclosures to customers, aligning with consumer protection laws and regulations in various jurisdictions.
• Service Provision Standards: Deposit-taking businesses should provide banking services efficiently, honestly, and fairly.
• Client Asset Protection: ADIs are expected to safeguard client funds and ensure they are segregated from the bank's operational funds, in compliance with regulatory requirements.
• Transparency in Fee Structures: Deposit-taking businesses should ensure clear communication of fee structures to build trust with clients.

Resource Management Controls

• Resource Adequacy: Deposit takers should maintain adequate financial, technological, and human resources to support effective operations and regulatory compliance.
• Professional Competence: ADIs are expected to ensure that staff, particularly those in risk management, compliance, and customer service, possess the necessary skills and knowledge to fulfil their roles effectively.
• Adviser and Representative Competence: Advisers should be adequately trained and qualified to provide investment advice.

Reporting Controls

• Regulatory Reporting: ADIs should report operational, financial, and compliance information to regulatory bodies, ensuring transparency and adherence to regulatory standards.
• Record-Keeping: Deposit-taking businesses should maintain accurate and accessible records of customer transactions, account information, and compliance efforts, facilitating audits and regulatory reviews.

Transactional Controls

• Authorisation and Verification Procedures: ADIs should verify customer identities and transactions, aligning with AML/KYC regulations in jurisdictions like the EU or the US.
• Conflict of Interest in Transactions: Deposit takers should identify and manage potential conflicts of interest, ensuring decisions are made in the best interests of customers and comply with regulatory standards.

Licensing Solutions for Authorised Deposit-taking Institutions (ADIs)

• Financial Licensing Application Support: We provide comprehensive support for a wide range of ADIs' licensing applications, ensuring compliance with local and international regulations. Our services include:

• ADI's Financial Services Regulation (Australia): We assist ADIs in obtaining an Authorised Deposit-taking Institution (ADI) Licence from the APRA, helping your business become compliant with ADI Licencees' obligations under the Banking Act 1959 and relevant APRA guidelines.
• UK ADIs' Licensing Requirements: We support UK ADIs in obtaining the Building Society Authorisation from the Prudential Regulation Authority (PRA), helping your business become compliant with the requirements of the Building Societies Act 1986 and relevant AML regulations. Visit our Building Society licensing page for more information.
• USA ADIs' Licensing Requirements: We support USA ADIs in obtaining the charter from the Office of the Comptroller of the Currency (OCC) under the Home Owners' Loan Act, helping your business become compliant with relevant regulations. Visit our Savings and Loan Associations licensing page for more information.
• Singapore ADIs' Licensing Requirements: We support Singapore ADIs in obtaining the Finance Company Licence from the Monetary Authority of Singapore (MAS) under the Finance Companies Act and applicable MAS regulations, helping your business become compliant. Visit our Finance Company licensing page for more information.
• New Zealand ADIs' Licensing Requirements: We support New Zealand ADIs in obtaining the NBDT licence from the Reserve Bank of New Zealand (RBNZ), helping your business become compliant with the Deposit Takers Act 2023, the Non-bank Deposit Takers Act 2013, and the Banking (Prudential Supervision) Act 1989. Visit our Non-Bank Deposit Takers licensing page for more information.
• Cayman Islands ADIs' Licensing Requirements: We support Cayman Islands ADIs in obtaining the non-bank deposit taker licence for Class B or Class C Banks from the Cayman Islands Monetary Authority (CIMA) under the Banks and Trust Companies Law, helping your business become compliant.
• Bermuda ADIs' Licensing Requirements: We support Bermuda ADIs in obtaining the Banks and Deposit Companies Licence from the Bermuda Monetary Authority (BMA) under the Banks and Deposit Companies Act 1999, helping your business become compliant.
• British Virgin Islands (BVI) ADIs' Licensing Requirements: We support BVI ADIs in obtaining the Banks and Trust Companies Licence from the British Virgin Islands Financial Services Commission (BVI FSC) under the Banks and Trust Companies Act 1990, helping your business become compliant.
• Isle of Man ADIs' Licensing Requirements: We support Isle of Man ADIs in obtaining the Financial Services Licence from the Isle of Man Financial Services Authority (IOMFSA) under the Financial Services Act 2008, helping your business become compliant.
• International Governance Alignment: We provide strategic advice on aligning governance models for authorised deposit-taking institutions operating across multiple jurisdictions to meet diverse regulatory expectations while maintaining operational efficiency and regulatory compliance.

 

Policies and Procedures for Authorised ADIs’ Compliance Management

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective ADIs' compliance management.
• Effective Procedures for ADIs' Compliance Management: We draft and enhance a detailed set of procedures and protocols to meet the distinct needs of your business, focusing on efficient compliance, your business goals, and applicable authorised deposit-taking institutions' compliance requirements.
• Examples: These policies and procedures include, but are not limited to:

 

Operational Compliance

• Compliance Management Frameworks
• Compliance Monitoring Programs
• Compliance Calendars and Checklists
• Complaints Handling and Dispute Resolution Policies
• Compliance Training Manuals and Programs, as part of our regulatory compliance training solutions
• Obligation Registers
• Depositor Compensation Scheme Policies
• Incident Reporting Policies and Procedures
• Outsourcing Policies and Vendor Risk Management policies as part of our outsourced provider's compliance management solutions
• New Client Account Opening Policies and Procedures, as part of our customer onboarding solutions

 

Governance and Oversight

• Board Charters, Risk, Audit and Compliance Committee Charters, as part of our corporate governance solutions
• Codes of Conduct
• Delegations Registers
• HR Manuals and Policies
• ESG Compliance Policies
• Conflict of Interest Policies

 

Risk Management

• Risk Management Frameworks as part of our risk management solutions
• Risk Assessment Guidelines and Methodologies
• Whistleblowing Policies
• Internal Control Testing Methodologies
• Risk Registers and specialised risk registers like Health and Safety Risk Registers
• Cybersecurity Risk Management Policies

 

Audit and Assurance

• Compliance Assurance Programs as part of our compliance assurance solutions
• Internal Audit Policies and Programs as part of our internal control testing solutions
• Regulatory Reporting Procedures

 

Client and Market Conduct

• Marketing and Advertising Policies
• Deposit Interest Rate Policy and Procedures
• Fair Dealing Policy
• Fair Lending Policies

 

AML/CFT and Financial Crime Compliance

• AML/CFT Compliance Programs
• AML/CFT Risk Assessment
• Sanctions Compliance policies and procedures
• Fraud Prevention Protocols and Controls as part of our fraud prevention solutions
• ABC Policies

 

Privacy and Data Management

• Client Data Protection Policies
• Record-keeping Policies and Procedures and/or Data Governance Policies as part of our record-keeping compliance solution
• External Privacy Policies
• Internal Data Protection Compliance Programs

 

 

Compliance Training and Capacity Building

We focus on practical compliance and the application of training to real-world compliance scenarios and challenges that authorised deposit-taking institutions generally face. Our services include:

• Customised Compliance Training Solutions:  Specialised compliance training sessions for various teams, including management, compliance, operations, sales, and customer relations, focusing on APRA standards, applying ADIs' compliance management practices to your circumstances, risk awareness, and more.
• Up-to-date Regulatory Compliance Updates:  Keeping compliance officers, managers, CROs, COOs, and other Risk and Compliance team members informed of changes in ADIs' licensing requirements and regulations, AML/CFT updates, and changes in regulatory guidance.
• Data Analysis for Effective Compliance Monitoring: Covering training on compliance-related, data-based analysis and its results, including risk rating, internal control adjustments, resource and focus reallocation, and more.
• Workshops on Emerging AML Trends and Red Flags: Updating on new AML trends, red flags, typologies, and AML/CFT requirements for authorised deposit-taking institutions. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented authorised deposit-taking institutions' compliance, capacity planning, and resource allocation, covering:

• APRA standards
• Internal and external compliance reporting
• Effective governance over risk and compliance functions
• Organisation-wide risk assessment, risk rating methodologies and the development, management, and testing of corresponding internal controls, including controls testing methodologies and practical techniques.
• Authorised deposit-taking institutions' compliance reality, including outsourced provider monitoring, UAV management, incident management, product suitability assessments, advertising and marketing compliance, improvements in the client onboarding journey, transaction monitoring processes, and more.

• Further information: You can visit our Compliance Training Solutions page for more information on the compliance training services we offer to licensed financial institutions and financial service providers.

 

ADIs and AML/CTF Compliance

We offer a complete set of solutions covering authorised deposit-taking institutions' anti-money laundering (AML), financial crime and counter-terrorism financing (CTF) compliance. Our solutions include:

• Customer due diligence, screening, and customer onboarding solutions
• Development of transaction monitoring frameworks tailored to ADI specific ML/TF red flags and your business specifications
• AML advisory covering authorised deposit-taking institutions' compliance issues and challenges
• Drafting, testing, and updating AML policies and procedures
• AML training and capacity building
• Managed AML compliance solutions for deposit providers
• Internal and statutory AML/CFT audit solutions for authorised deposit-taking institutions
• Financial crime prevention framework development focusing on common fraud risks faced by authorised deposit-taking institutions.
• For more information, please visit our specialised ADI AML Compliance Solutions page

ADIs’ Compliance Technology Integration

Our services cover compliance aspects concerning the integration of technology for risk and compliance e-management, transactional reporting (where applicable), usage of AI, technology outsourcing, and compliance aspects of third-party risk management for authorised deposit-taking institutions, including:

• Needs Assessment
• Compliance Technology Selection: Based on your budget, products, available operational and technical resources, and the applicable authorised deposit-taking institutions' compliance obligations
• Implementation assistance across the organisation
• Streamlining operational workflows: For routine compliance tasks like data collection, reporting, and risk assessments
• AML/CFT Compliance Technology: Covering customer digital onboarding, E-KYC, PEP and sanctions screening, transaction monitoring, etc.
• Integration of authorised deposit-taking institutions' compliance obligations into an effective CRM system
• Record-Keeping Obligations: Helping you choose and integrate the necessary tools to comply with the record-keeping requirements under various laws and APRA standards

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting authorised deposit-taking institutions in establishing robust data governance procedures, programs, and protocols that align data collection, storage, and usage practices with relevant data privacy regulations, such as GDPR, CCPA, and other applicable laws. These measures safeguard sensitive client and business information from unauthorised access, breaches, and misuse.
• Privacy Policy Compliance Monitoring: Helping you implement privacy policies that reflect the latest data protection legislation, supported by continuous compliance monitoring tools to maintain the highest data privacy standards.
• Record Maintenance Protocols:  We assist in developing and implementing effective procedures for maintaining necessary records, covering authorised deposit-taking institutions' compliance with applicable regulatory reporting standards and reporting requirements.
• Record Availability and Inspection Readiness:  ADI related regulations often require records to be readily available for inspection by regulators, AML/CFT supervisors, tax agencies, and other relevant authorities. This extends to information kept by your outsourced service providers. We help you organise your record-keeping processes to meet these needs.

 

ISO Standards and ADIs’ Compliance

• Cross-Reference Mapping: Integrating ISO standards such as ISO 27001, ISO 9001, and ISO 22301 into an existing compliance framework and linking specific sections of ISO standards to corresponding procedures in your internal policies and procedures.
• Pre-Audit Preparation: Coordinating ISO controls testing across different parts of the business.
• Leading evidence collection across the different departments to cover relevant compliance areas such as planning, governance, organisational controls, operational controls, technological controls, and physical controls through structured workflows.
• Digital Compliance Repository: Helping you utilise a centralised digital repository for storing all compliance-related documents and evidence, making it easily accessible for audit purposes and compliance verification.
• ISO Audit Liaison:  Acting as a liaison between your team and the auditors, coordinating information requests, and ensuring all the necessary documentation is readily available.
• Post-Audit Remediation Management: We can lead the implementation of your remediation plan and support corrective actions to address all audit findings effectively.

 

Regulatory Change Management Solutions

Empower Your Business with Proactive Regulatory Change Management:

• Stay Ahead of the Curve:  We actively monitor regulatory updates from global financial authorities like MAS, ASIC, FMA, FCA, SEC, and other regulators for authorised deposit-taking institutions' compliance changes and updates to evaluate the implications of regulatory changes.
• Impact Assessment and Mitigation Strategies: We analyse the potential impact of regulatory changes on ADIs' compliance management frameworks and operational processes. We then collaborate with you to develop effective mitigation strategies that support continued compliance and minimise disruption.
• Seamless Implementation and Change Management:  We guide authorised deposit-taking institutions through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.