Specialised Solutions for Brokers’ Compliance Management

We offer a comprehensive set of risk and compliance solutions tailored to a variety of brokers' compliance obligations. We can help you comply with broker regulations in a commercially oriented and goal-focused manner, providing a tailored approach to brokers' compliance management with regard to your specific circumstances, including:

• Your commercial objectives
• Brokerage services and products you offer
• Your business size
• Your technology and human resources
• Your risk appetite
• Your governance structure
• Your client demographics
• Your countries of operation, their applicable laws, and relevant brokers' licensing requirements and regulations, including key aspects such as outsourced providers' monitoring, compliance training, risk management, audit, and assurance.
• Any related compliance obligations, including, but not limited to, brokers' obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, fair trading laws, and more.
• Brokers' 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 brokers and broker-dealers, 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 broker regulation and brokers' licensing requirements in the following jurisdictions:

• Australia: Where finance brokers, stock brokers, and mortgage brokers should comply with the Australian Securities and Investments Commission's (ASIC) regulations under the Corporations Act 2001  and the National Consumer Credit Protection Act 2009. Finance brokers and stock brokers require an Australian Financial Services Licence (AFSL), while mortgage brokers require an Australian Credit Licence (ACL).
• United States: Where stock brokers and broker-dealers should register with the Securities and Exchange Commission (SEC) and become members of FINRA, governed by the Securities Exchange Act of 1934. Mortgage brokers are regulated at the state level and should comply with federal laws such as the Truth in Lending Act and the Real Estate Settlement Procedures Act.
• United Kingdom: Where the Financial Conduct Authority (FCA) oversees finance and stock brokers, requiring authorisation under the Financial Services and Markets Act 2000. Mortgage brokers should also be authorised by the FCA and comply with the Mortgage Credit Directive (MCD).
• Singapore: Where finance brokers and stock brokers should obtain a Capital Markets Services Licence under the Securities and Futures Act. Mortgage brokers should comply with guidelines set by the Monetary Authority of Singapore (MAS).
• New Zealand: Where all brokers should register on the Financial Service Providers Register (FSPR) as per the Financial Service Providers (Registration and Dispute Resolution) Act 2008.
• European Union: Where finance and stock brokers should comply with the Markets in Financial Instruments Directive (MiFID II). Mortgage brokers should adhere to the Mortgage Credit Directive (MCD), which is implemented through national laws.

 

 

What Types of Brokers Do We Support?

Our compliance solutions cover the following types of brokers and brokerage firms:

• Finance Brokers, which deal with a wide range of financial products and services.
• Stock Brokers, which handle securities trading and must comply with market conduct standards.
• Mortgage Brokers, who arrange mortgage loans and are subject to licensing and consumer protection regulations.
• Insurance Brokers, who deal with insurance products and must ensure regulatory compliance and consumer protection.
• Forex Brokers, which trade in foreign exchange markets and must adhere to risk management and reporting obligations. Please visit our dedicated Risk and Compliance Solutions page for Forex Brokers for more information.

 

Brokers’ Compliance Advisory

Our focus areas include:

• Detailed Compliance Advice: Covering brokers' compliance management issues across the first, second, and third lines, as well as matters related to effective compliance with financial markets regulations and brokers' 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 the brokers' AML/CFT requirements.
• Operational Compliance Advice: Advising compliance, management, technology, and support teams on the day-to-day compliance with broker regulations, focusing on internal processes and critical internal controls for effective brokers' compliance management.
• Risk Management Advice: Covering risk rating and methodologies, risk assessments, management, and mitigation for various risk types faced by brokers, 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 brokers' 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 brokers' compliance obligations effectively, improve internal governance and reporting, and optimise them for market expansion and growth.
• Brokers' Licensing Advice: We can guide you through the licensing process, help you apply regulations to your specific circumstances and business environment, and meet brokers' 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 Brokers' Compliance Issues: We can help you resolve specific risk or compliance issues related to broker regulations 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 brokers and other licensed financial institutions, financial services providers, and regulated businesses.

 

 

Reporting and Regulatory Liaison Solutions for Brokers’ 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 brokers 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 brokers' 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 brokers' compliance management of reporting obligations under various laws and regulations, including submitting SAR, SMR, STR, PTR, TTR, specific reportable matters under the brokers' licensing requirements and other externally reportable transactions and activities.
• Internal Quality Assurance Reporting: While second-line control testing is crucial for complying with broker regulations, including brokers' 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 Brokers

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

• Brokers' Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable brokers' 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 broker regulations 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 brokers' 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 brokers' 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 brokers' 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 brokers.
• 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 brokers' 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.
• Brokers' 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 brokers' compliance obligations, including brokers' 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.

 

Brokers’ 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 broker regulations 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 brokers' compliance obligations, including brokers' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable broker regulations. 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 brokers' 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 brokers 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 brokers 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 brokers 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 Brokers’ 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 brokers' compliance obligations.

We go beyond merely quoting broker regulations 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 brokers' compliance requirements include:

Regulatory Controls and Brokers’ Licensing Requirements 

• Compliance Management: Brokers should have robust compliance management systems, including conflict of interest management and insider trading prevention measures. This is especially critical for share brokers who handle sensitive market information, mortgage brokers who should manage client confidentiality and ethical lending practices, and finance brokers who need to adhere to stringent advisory standards.
• Liquidity Management: Broking service providers managing client funds or offering margin trading should maintain adequate liquidity to meet their financial obligations promptly. This is crucial for share brokers dealing with high-volume transactions and margin accounts, as well as finance brokers managing client investments.
• Capital Adequacy: Brokers, especially share brokers under securities regulations, may need to maintain minimum capital levels to ensure financial stability. Mortgage brokers should also ensure they have adequate financial resources to cover loan obligations and operational costs.
• Financial Auditing: Licensed brokers should engage qualified editors to conduct regular audits to verify compliance with regulatory standards and ensure financial stability. This applies to all types of brokers: share brokers to verify trading practices, mortgage brokers to confirm loan compliance and financial health, and finance brokers to ensure investment advice is backed by sound financial practices.
• Regulated Counterparty Engagement: Broking businesses may have rules about engaging with regulated financial institutions for clearing, settlement, and other financial services. Share brokers should ensure their trades are settled through regulated entities, mortgage brokers must collaborate with licensed lenders and clearinghouses, and finance brokers must work with regulated investment and banking partners.
• Cross-Border Application of Regulations: Brokers should comply with international brokerage and financial service regulations when operating or serving clients across borders. This is particularly relevant for share brokers involved in international markets, mortgage brokers offering cross-border mortgage solutions, and finance brokers providing global investment advisory services.
• Digital Payment Token Services: With the rise of cryptocurrencies and digital assets, regulators have set out specific regulations for brokers dealing with digital payment tokens. These regulations may not be fully covered under traditional financial regulations and often require brokers to comply with additional requirements specific to digital assets. This is relevant for all types of brokers, including share brokers trading in digital assets, mortgage brokers accepting crypto as collateral, and finance brokers advising on cryptocurrency investments.

 

Operational Oversight Controls

• Technology Risk Management:
  • Share Brokers: Should manage risks associated with electronic trading platforms, ensuring cybersecurity and system reliability.
  • Mortgage Brokers: Should implement IT security measures for handling sensitive client data and online application processes.
  • Finance Brokers: Need robust systems for managing client advisory platforms and ensuring data protection.
• Outsourcing Oversight:
  • Share Brokers: Should maintain control over outsourced functions like IT services, customer support, and clearing services.
  • Mortgage Brokers: Should oversee outsourced functions such as loan processing and customer service.
  • Finance Brokers: Should monitor outsourced financial advisory services and IT support to ensure compliance.
• Risk Management:
  • Share Brokers: Should manage market and credit risks, particularly with leveraged products.
  • Mortgage Brokers: Should focus on operational and credit risks associated with loan approvals and client interactions.
  • Finance Brokers: Need to manage risks related to investment advisory and market fluctuations.
• Governance Arrangements:
  • Share Brokers: Should have governance structures to oversee trading activities and regulatory compliance.
  • Mortgage Brokers: Need effective governance for loan approval processes and client management.
  • Finance Brokers: Should ensure governance arrangements for overseeing investment advice and client interactions.
• Senior Management Accountability:
  • Share Brokers: Senior managers should ensure ethical trading practices and client protection.
  • Mortgage Brokers: Leaders should be accountable for ethical lending practices and regulatory compliance.
  • Finance Brokers: Senior managers should oversee ethical advisory practices and compliance with financial regulations.
• Operational Resilience:
  • Share Brokers: Should have continuity plans for trading operations and client fund access.
  • Mortgage Brokers: Need plans for continued client service and loan processing during disruptions.
  • Finance Brokers: Should ensure resilience in advisory services and data management.
• Advanced Order Types and Execution Policies:
  • Share Brokers: Should communicate advanced order types and execution policies clearly to clients.
  • Finance Brokers: Should ensure transparency in execution policies for investment products.

 

Market Integrity and Transparency Controls

• Market Conduct Standards:
  • Share Brokers: Should ensure fair and transparent market conduct, free from manipulation or insider trading.
  • Mortgage Brokers: Should adhere to ethical lending practices and transparent client interactions.
  • Finance Brokers: Should maintain high standards of conduct in investment advice and client dealings.
• Fair Dealing Principles:
  • Share Brokers: Should treat clients fairly, with transparent fee structures.
  • Mortgage Brokers: Should ensure fair treatment and clear communication about loan products.
  • Finance Brokers: Should adhere to fair dealing principles when providing financial advice and investment products.
• Conduct and Disclosure Standards:
  • Share Brokers: Should disclose brokerage policies, fees, and risks clearly to clients.
  • Mortgage Brokers: Should provide transparent information about loan terms and conditions.
  • Finance Brokers: Need to maintain high standards for disclosing advisory fees and investment risks.
• Service Provision Standards:
  • Share Brokers: Should provide services efficiently and in the best interest of clients.
  • Mortgage Brokers: Should ensure efficient and transparent loan processing.
  • Finance Brokers: Should provide high-quality advisory services that meet client expectations.
• Client Asset Protection:
  • Share Brokers: Should segregate client funds and adhere to custody rules.
  • Mortgage Brokers: Should ensure client data and documents are securely stored.
  • Finance Brokers: Should safeguard client investments and ensure proper custody of assets.
• Transparency in Relationship with Market Makers:
  • Share Brokers: Should disclose relationships with market makers or liquidity providers to clients.
  • Finance Brokers: Should inform clients about any relationships with financial product providers.
• Dispute Resolution:
  • Share Brokers: Should have mechanisms for resolving client disputes effectively.
  • Mortgage Brokers: Should provide clear procedures for handling client complaints.
  • Finance Brokers: Need proper mechanisms for dispute resolution and client compensation.

 

Resource Management Controls

• Resource Adequacy:
  • Share Brokers: Should maintain sufficient resources for trading operations and client support.
  • Mortgage Brokers: Should ensure adequate resources for loan processing and client service.
  • Finance Brokers: Need to maintain resources for effective advisory services and compliance.
• Professional Competence:
  • Share Brokers: Should ensure staff involved in trading possess the necessary skills and knowledge.
  • Mortgage Brokers: Should ensure loan officers and support staff are well-trained.
  • Finance Brokers: Need to ensure advisors are competent and knowledgeable about financial markets.
• Adviser and Representative Competence:
  • Share Brokers: Staff should be trained in trading strategies and market regulations.
  • Mortgage Brokers: Staff should be knowledgeable about loan products and lending regulations.
  • Finance Brokers: Advisors should be trained in investment strategies and regulatory requirements.

 

Reporting Controls

• Market Transaction Reporting:
  • Share Brokers: Should report trades and transactions accurately and timely.
  • Finance Brokers: Should report client transactions accurately for compliance.
• Comprehensive Transaction Reporting:
  • Share Brokers: Should ensure comprehensive reporting of all client transactions.
  • Mortgage Brokers: Should maintain detailed records of loan transactions.
  • Finance Brokers: Need comprehensive reporting for client investment transactions.
• Regulatory Reporting:
  • Share Brokers: Should conduct regular reporting to regulatory authorities.
  • Mortgage Brokers: Should report to relevant regulatory bodies on loan activities.
  • Finance Brokers: Need to report on advisory activities and compliance.
• Record-Keeping:
  • Share Brokers: Should maintain accurate records of trades and client communications.
  • Mortgage Brokers: Should keep detailed records of loan applications and client interactions.
  • Finance Brokers: Need to maintain records of client transactions and advisory services.
• Real-time Transaction Monitoring:
  • Share Brokers: Should monitor transactions in real-time to detect and address unusual trading patterns.
  • Finance Brokers: Should monitor investment transactions to ensure compliance and detect anomalies.

 

Product and Service Management Controls

• Product Suitability:
  • Share Brokers: Should ensure trading products are suitable for clients' risk profiles.
  • Mortgage Brokers: Should offer loan products suitable for clients' financial situations.
  • Finance Brokers: Need to recommend investment products that fit clients' needs and risk tolerance.
• Product Lifecycle Oversight:
  • Share Brokers: Should manage the entire lifecycle of trading products from introduction to review.
  • Mortgage Brokers: Should oversee loan products from application to repayment.
  • Finance Brokers: Need procedures for managing investment products throughout their lifecycle.
• Execution Quality:
  • Share Brokers: Should ensure the best possible execution of client orders.
  • Mortgage Brokers: Should ensure efficient processing of loan applications.
  • Finance Brokers: Need to ensure high-quality execution of investment transactions.
• Data Protection and Privacy:
  • Share Brokers: Should adhere to data protection standards to safeguard client information.
  • Mortgage Brokers: Should ensure client data is securely handled and protected.
  • Finance Brokers: Need to comply with data privacy laws to protect client information.

 

Transactional Controls

• Best Execution Oversight:
  • Share Brokers: Should ensure client transactions are executed at the best available terms.
  • Mortgage Brokers: Should secure the best possible loan terms for clients.
  • Finance Brokers: Should ensure investment transactions are executed favourably for clients.
• Authorisation and Verification Procedures:
  • Share Brokers: Should verify client identities and ensure compliance with KYC regulations.
  • Mortgage Brokers: Should perform thorough identity checks and verification.
  • Finance Brokers: Need to ensure proper authorisation and verification of client identities.
• Conflict of Interest in Transactions:
  • Share Brokers: Should identify and manage conflicts of interest in trading activities.
  • Mortgage Brokers: Should manage conflicts in loan recommendations.
  • Finance Brokers: Should address conflicts in investment advice and transactions.
• Monitoring of Leveraged and Complex Transactions:
  • Share Brokers: Should oversee leveraged trading and complex strategies to align with client risk profiles.
  • Finance Brokers: Should monitor complex investment transactions for risk management.
• Periodic Review and Reconciliation:
  • Share Brokers: Should conduct regular reviews of trading activities and client accounts.
  • Mortgage Brokers: Should review loan accounts periodically for accuracy.
  • Finance Brokers: Need to reconcile client investment accounts regularly.
• Enhanced Due Diligence for High-Risk Clients:
  • Share Brokers: Should apply enhanced due diligence for high-volume or complex trading clients.
  • Mortgage Brokers: Should conduct thorough checks for high-risk loan applicants.
  • Finance Brokers: Need to perform enhanced due diligence for high-risk investment clients.
• Digital Asset and Cryptocurrency Trading:
  • Share Brokers: Should comply with specific regulations for trading digital assets.
  • Finance Brokers: Should ensure compliance when advising or dealing in cryptocurrencies.
• Security of Digital Wallets and Transactions:
  • Share Brokers: Should implement robust security measures for digital asset storage and transactions.
  • Finance Brokers: Need to secure digital wallets and transactions for client protection.
• Investor Education Programs:
  • Share Brokers: Should develop programs to educate clients on trading risks and strategies.
  • Mortgage Brokers: Should provide information on mortgage options and financial implications.
  • Finance Brokers: Should offer education on investment risks and financial planning.
• Dedicated Support for Trading Platforms:
  • Share Brokers: Should offer technical support for trading platforms to ensure seamless client experience.
  • Mortgage Brokers: Should provide support for online loan application systems.
  • Finance Brokers: Need to offer support for advisory and investment platforms.

 

Licensing Solutions for Brokers

• Financial Licensing Application Support: We provide comprehensive support for a wide range of financial licensing applications and registration for broking businesses and firms.

Australia:

• AFSL Application Assistance for Australian Brokers: We can provide comprehensive support for navigating ASIC's AFSL application process.
• ACL Application Assistance for Australian Mortgage Brokers: We can guide brokers through ASIC's application process for an Australian Credit Licence.
• Further Information about Brokers' Licensing Requirements in Australia: Please visit our AFS Licensing Solutions page for Brokers.

New Zealand:

• FSPR Registration Guidance in New Zealand: We can facilitate the registration process for brokers on New Zealand's FSPR.
• Further Information about Broker Regulations in New Zealand: Please visit the FSP Registration page.

United Kingdom:

• FCA Authorisation Support for UK Brokers: We can assist brokers in the UK with the FCA authorisation process to ensure compliance with financial services regulations. This includes support for mortgage brokers in obtaining FCA authorisation and navigating both FSMA and MCD requirements.
• Further Information about Broker Regulations in the UK: Please visit our FCA Authorisation page for Brokers.

United States of America:

• SEC and FINRA Registration for U.S. Stock Brokers and Broker-Dealers: We can offer guidance for SEC registration and FINRA membership, including compliance with state-specific licensing and registration through NMLS, ensuring adherence to both state and federal regulations.
• Further Information about Brokers' Licensing Requirements in the US: Please visit our Broker-Dealer Registration page for Brokers.

Singapore:

• Capital Markets Services Licence Application in Singapore for Stock Brokers: We can help Singaporean brokers obtain the necessary MAS licence for securities trading.
• Guidance for Singapore Mortgage Brokers:  We can advise on fair dealing practices as per MAS guidelines.
• Further Information about Brokers' Licensing Requirements in Singapore: Please visit Capital Markets Services Licence page.

 

European Union:

• MiFID II Compliance for EU Brokers: We support brokers across the EU in complying with the Markets in Financial Instruments Directive (MiFID II), ensuring adherence to stringent regulatory standards.
• Compliance Advisory for Mortgage Brokers in the EU: We provide guidance on aligning practices with the MCD and local member state regulations.

• International Governance Alignment: We provide strategic advice on aligning governance models for brokers operating across multiple jurisdictions to meet diverse regulatory expectations while maintaining operational efficiency and regulatory compliance.

 

Policies and Procedures for Brokers’ Compliance Management

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective brokers' compliance management.
• Effective Procedures for Brokers' 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 brokers' 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
• Margin Account Negative Balance Write-Off Procedures
• 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
• Whistleblowing Policies
• Conflict of Interest Policies

 

Risk Management

• Risk Management Frameworks as part of our risk management solutions
• Risk Assessment Guidelines and Methodologies
• Internal Control Testing Methodologies
• Risk Registers and specialised risk registers like Health and Safety Risk Registers
• Cybersecurity Risk Management Policies
• Best Execution Policies
• Algorithmic Trading and High-frequency Trading (HFT) Oversight

 

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 Policy
• Staff Dealing and Insider Trading Policy
• Fair Lending Policy
• Investor Education Programs

 

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 brokers 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 broker regulations, applying brokers' 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 brokers' 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 brokers. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented brokers' compliance, capacity planning, and resource allocation, covering:

• Broker Regulations
• 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.
• Brokers' 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.

 

Brokers and AML/CTF Compliance

We offer a complete set of solutions covering brokers' 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 brokers' specific ML/TF red flags and your business specifications
• AML advisory covering brokers' compliance issues and challenges
• Drafting, testing, and updating AML policies and procedures
• AML training and capacity building
• Managed AML compliance solutions for broking firms and businesses
• Internal and statutory AML audit solutions for brokers
• Financial crime prevention framework development focusing on common fraud risks faced by brokers.
• For more information, please visit our specialised AML/CFT Compliance Solutions page for Borkers

 

Brokers’ 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 brokers, including:

• Needs Assessment
• Compliance Technology Selection: Based on your budget, products, available operational and technical resources, and the applicable brokers' 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 brokers' 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 broker regulations

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting brokers 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 brokers' compliance with applicable regulatory reporting standards and reporting requirements.
• Record Availability and Inspection Readiness:  Broker regulation often requires 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 Brokers’ 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 brokers' 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 brokers' 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 brokers through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.