A Compliance Monitoring Program (CMP) is a structured approach to managing compliance within an organisation, ensuring adherence to both external regulations and internal policies. At its core, a CMP aims to avoid penalties, maintain reputation, ensure ethical operations, reduce the risk of non-compliance penalties, and foster a strong compliance culture.
CMP involves:
- Identifying Relevant Regulations and Internal Policies: Recognising applicable external laws, industry-specific regulations, and internal organisational policies.
- Creating a Monitoring Plan: Developing specific checks, timelines, and methodologies for ongoing compliance assessment.
- Implementing Controls and Procedures: Establishing effective controls and procedures to prevent instances of non-compliance.
- Communicating Findings in a clear reporting format.
The essential elements of a robust CMP include:
- Core Functions:Â Continuous tracking, regulatory monitoring, mitigation strategies, control evaluations, and maintaining a comprehensive checklist of necessary compliance activities throughout the year.
- Compliance Performance Indicators: Utilising internal controls mapping, process maps, dashboards, analytics, and standardised control assessment and scoring methodologies to measure compliance performance.
- Compliance calendar and checklist: Having effective mechanisms for implementation of the program.
- Fit for Purpose:Â Tailoring the CMP to consider roles and responsibilities, the size of the business, available technology (including integrated compliance management systems), and the specific laws and regulations relevant to the organisation.
- Relation to Risk Assessment: Incorporating findings from risk assessments, including residual risk methodologies, likelihood and impact evaluations, and clear risk ratings to prioritise compliance activities effectively.
- Flexibility: Designing the CMP to accommodate additional processes and incorporate necessary triggers and indicators, such as corrective action plans, compliance gap analyses, or risk reassessments. For example, a corrective action plan, a compliance gap analysis in a certain area, and a reassessment of certain risks.
- Compliance Governance and Oversight: Establishing effective compliance reporting mechanisms to ensure transparency and accountability.
- Integration with Other Compliance Efforts: Embedding the CMP within the broader compliance management framework, aligning it with compliance assurance programs, internal audits, and external audit efforts. This way, the program will remain current with evolving regulations and organisational changes.
- Documenting Findings and Taking Corrective Actions: Recording compliance-related findings and addressing identified issues promptly.
Our service
We design and implement Compliance Monitoring Programs (CMPs) tailored to meet your organisation's specific compliance needs, with effective adherence to regulatory requirements and internal policies and documents.
Our Compliance Monitoring Programs are tailored to meet your compliance needs in a commercially feasible manner with regard to your specific circumstances, including:
- Your commercial objectives
- Products you offer
- The size of your business
- The available technology
- Your risk appetite
- Your governance structure
- Client demographics
- Your countries of operation, their applicable laws, regulations and licensing requirements
We address compliance obligations in areas including:
- Regulatory Compliance
- Compliance with Financial Licensing requirements
- Operational Oversight
- Market Integrity & Transparency
- Resource Management
- Reporting
- Product and Service Management
- Transactional Monitoring
- Operational processes, including but not limited to:
- Transaction Monitoring
- Reporting
- Outsourced Providers Review
- Recordkeeping
- Conflict of interest management
Our CMPs solutions cover:
- Compliance Calendars & Checklists: We develop detailed compliance calendars to schedule and track all compliance activities, ensuring no deadlines are missed.
- Compliance Obligations Register: We create and maintain a comprehensive register of all applicable compliance obligations specific to your industry and jurisdiction.
- Internal Reporting Structures: Establishing clear lines of communication and reporting within your organisation to facilitate effective compliance tracking and issue escalation.
- Controls testing Methodologies: Covering controls evaluation, effectiveness rating and testing methodologies for different departments.
- Control Testing and Monitoring: Providing clear guidelines for regular testing of internal controls, assessing their effectiveness, and relevant follow-up actions. This includes:
- AML/CTF Controls: customer due diligence, transaction monitoring, ongoing due diligence, record keeping, transactional reporting, enhanced due diligence measures, suspicious matter and activity reporting, ML/TF red flags and indicators effectiveness, etc.
- Fraud Prevention
- Banking Controls
- Marketing
- Sales
- Governance
- Risk Management
- ISO controls
- Policy and core documents review: Oversight mechanisms to ensure that these are updated when required.
- External Reporting Oversight:Â Oversight mechanisms covering event based and periodic reporting to ensure that relevant matters are reported to your regulators.
- Compliance Training Oversight: Oversight mechanisms to ensure that training is conducted and compliance training manuals and programs remain relevant.
- Incident Reporting Oversight: Oversight mechanisms to test your incidents management and issue management protocols.
- Continuous Compliance Tracking: Compliance actions are required when it comes to regulatory change management, changes in your risk ratings and risk assessment methodologies, roles and responsibilities in compliance management, internal and external audit outcomes, including compliance gap analysis findings.
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Types of Entities We Help
We deliver compliance monitoring programs for a wide range of entities, including:
- Non-bank deposit takers and non-bank lenders, including neo-banks, building societies, and savings and loan associations
- Consumer credit providers, credit unions, finance companies and corporate finance providers
- Investment bankers, investment firms, and fund managers,
- Derivatives issuers, derivatives platforms and traders
- Financial advisers, investment advisers, and wealth managers
- Brokers, including forex brokers
- Custodial or depository services providers and licensed trustees
- P2P lending platforms and crowdfunding services
- Fintech and InsureTech companies
- Insurance providers, including life and maritime insurance providers
- Online casinos and gambling platforms
- Currency exchange providers, e-money issuers, money remitters, and money transmitters
- Company and trust formation specialists, real estate businesses, audit firms, law firms and professionals
Our compliance monitoring programs work well for financial institutions and financial service providers based on the following:
- Australia
- United States
- United Kingdom
- Singapore
Hong Kong - New Zealand
- European Union
- Offshore formation centres such as Dubai, the Cayman Islands, Bermuda, Malta, Seychelles, Vanuatu, Panama, Belize, the British Virgin Islands, etc.
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Compliance Monitoring Program Design
We focus on the effectiveness and efficiency of your CMP to make sure it is fit for purpose in your circumstances, aligning compliance with your business strategy, objectives, and resources. Also focusing on:
- Implementing clear internal reporting structures for efficient communication, testing, tracking and evidence collection
- Â Developing an effective compliance monitoring system with effective tests and compliance oversight processes
- Ensuring that your monitoring programs are scalable and adaptable to both internal and external changes
- Distinguishing regulatory compliance obligations from what you do above those to prepare for regulatory reviews and audits adequately
Compliance Monitoring Program Implementation
We assist businesses in the implementation of their Compliance Monitoring Programs by:
- Integrating compliance management software and compliance monitoring tools, including RegTech solutions and automated compliance solutions, for real-time monitoring
- Ensuring alignment of the CMP with your reporting schedule
- Establishing compliance calendars and checklists to organise compliance tasks.
- Training staff to perform activities set out in the CMP
- Tracking the CMP’s performance and incorporating feedback for ongoing improvements
- Supporting the CMP’s flexibility to adapt to real-life risk and compliance environments
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Compliance Monitoring Program and Reg-tech
We can help you select and integrate appropriate regulatory technology (RegTech) solutions tailored to CMP delivery, your specific risk and compliance obligations, budget, and technical infrastructure to enhance efficiency and effectiveness. The focus is to help you:
- Streamline operational workflows: Automate routine compliance tasks such as data collection, reporting, task performance tracking, reminders, and linking CMP efforts to your risk assessments and risk management frameworks.
- Automate compliance monitoring processes: Reduce manual workloads and increase accuracy by automating compliance monitoring processes, freeing up resources for more strategic compliance activities.
Additionally, we can help you with RegTech for your first line of compliance defence to:
- Utilise advanced compliance monitoring tools: Implement tools for real-time regulatory compliance monitoring to allow immediate identification and resolution of compliance issues.
- Enhance internal controls implementation: Use technology-driven solutions to strengthen internal controls, helping with their effectiveness and alignment with compliance requirements.
Our services also include:
- Needs assessment
- Technology selection: Tailored to your budget, operations, and compliance obligations
- Testing: Assisting with testing to validate functionality, usability, and integration with operational, risk management, and compliance structures
- Implementation and customisation assistance
- Internal documentation alignment: Streamlining internal documentation, including compliance-related policies, procedures, workflows, and process maps, to accommodate the technology selection
Compliance Monitoring Program Enhancement
We offer CMP enhancements to increase the overall effectiveness of your compliance efforts, reflecting on:
- New compliance requirements, changes to the existing regulatory regime, and adaptations to regulatory compliance guidance
- Business growth and expansion
- Changes in risk ratings, risk appetite, identified new risks, and changes in risk profiles
- Changes in your compliance policy
- Auditors' and regulators' findings, including identified deficiencies and breaches
- Internally identified areas of improvement and gaps
- Results of previous internal controls testing
- Introduction of new products
- Other triggering events
Compliance Monitoring Program Review
Regular CMP reviews can help your compliance function and senior management manage compliance effectively. We offer thorough CMP reviews to assess its effectiveness and fitness for purpose. Our focus areas include identifying:
- Any gaps
- Points of improvement
- Necessary changes to compliance calendar activities
- Necessary changes to control testing methodologies
- Required adjustments related to changes in your resources and operations
- Required adjustments related to the introduction of new products, expansion to new jurisdictions, and more
We offer this service either as:
- A standalone solution
- As part of our compliance advisory solution. For more information about coverage, please visit our Compliance Advisory Solution page.
- As part of our second-line compliance management solution. For more information about coverage, please visit our Compliance Management Solution page.
Compliance Monitoring Programs for Small Businesses and Startups
Getting things right from the get-go is important. It is better to be compliant than sorry. We develop compliance CMPs for small businesses, focusing on establishing foundational compliance that can help you remain compliant and grow without compliance becoming a hindering business factor.
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Compliance Monitoring Programs for Company Groups
Managing compliance across multiple products and jurisdictions is a complex challenge that requires efficient resource allocation, prioritisation of key areas, and attention to detail without sacrificing overall efficiency.
For company groups with multiple subsidiaries, we offer compliance monitoring programs that:
- Harmonise compliance efforts across all entities
- Facilitate centralised tracking and reporting of compliance activities
- Prioritise compliance tasks based on risk and regulatory requirements
- Can effectively be used to develop group-wide compliance calendars and obligation registers
- Support management in overseeing group-wide compliance operations
- Address complex and dynamic regulatory landscapes
Our extensive experience with multi-jurisdictional financial institutions allows us to tailor Compliance Monitoring Programs to effectively manage compliance risks across diverse business units and locations.
Compliance Monitoring Program for High-risk Corporates
High-risk corporates face heightened regulatory scrutiny. With years of experience helping high-risk corporations remain compliant, we develop CMPs that go into the necessary depth to help entities avoid compliance issues and successfully address compliance challenges.
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Compliance Monitoring Program Template
Our CMP templates are flexible and adaptable to:
- operational, internal, and regulatory differences
- business size, available compliance resources
- available technology
- markets of operation
- products
- different risk and compliance requirements from different laws, regulations, and financial licensing regimes
- your compliance history
- your compliance goals
- your wider business goals
- regulatory changes
- specific risk and compliance challenges you face
Compliance Monitoring Program in Context
In terms of a general compliance documentary pack, a CMP should generally align with:
- Controls Management Framework (CMF):Â A high-level structure outlining the organisation's approach to identifying, assessing, and mitigating risks. This document provides the foundation for implementing controls to ensure compliance. Please visit our CMF page for more information.
- Risk Management Framework:Â A comprehensive system of policies, procedures, and controls designed to identify, assess, mitigate, and monitor risks that could impact an organisation's objectives. Please visit our Risk Management Solutions page for more information.
- Compliance Documents covering specific areas of compliance. For example, AML/CFT Compliance Programs, Data Retention policies, outsourcing policies, etc.
On a broader scale, a CMP is often supplemented by:
- AÂ Compliance Assurance Program (CAP):Â A systematic approach to evaluating the effectiveness of an organisation's compliance framework and controls. It aims to provide reasonable assurance that the organisation is complying with relevant laws, regulations, and internal policies. We offer this service as part of our compliance assurance solutions. Please visit our CAP page for more information.
