Specialised Solutions for Wealth Managers’ Compliance Management

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

• Your commercial objectives
• Your business goals
• Your wealth management and investment solutions
• 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 wealth managers' 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, wealth managers' obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, fair trading laws, and more.
• Wealth managers' 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 wealth managers, 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 wealth management regulations and wealth managers' licensing requirements compliance in the following jurisdictions:

• Australia: Where wealth managers dealing with retail clients are regulated by the Australian Securities and Investments Commission (ASIC) under the Corporations Act 2001, requiring an Australian Financial Services Licence (AFSL). Wealth managers servicing wholesale clients generally still require an AFSL, but may benefit from reduced compliance obligations under the Corporations Act compared to those servicing retail clients.
• New Zealand: Where wealth managers dealing with retail clients are regulated by the Financial Markets Authority (FMA) under the Financial Markets Conduct Act 2013, requiring a Managed Investment Scheme (MIS) Manager Licence. Wealth managers servicing wholesale clients must register on the Financial Service Providers Register (FSPR) and comply with relevant financial service provider regulations.
• United Kingdom: Where wealth managers are regulated by the Financial Conduct Authority (FCA) under the Financial Services and Markets Act 2000, requiring FCA authorisation for all client types with specific regulatory requirements for retail versus professional clients.
• United States: Where wealth managers are regulated by the Securities and Exchange Commission (SEC) or state securities authorities under the Investment Advisers Act of 1940, requiring registration as Investment Advisers for both retail and institutional clients, with differing obligations and disclosures.
• Singapore: Where wealth managers dealing with retail clients are regulated by the Monetary Authority of Singapore (MAS) under the Securities and Futures Act, requiring a Capital Markets Services Licence (CMSL). Wealth managers servicing only accredited or institutional clients can operate as Registered Fund Management Companies (RFMCs), which must register with MAS but do not require a CMSL, provided they meet certain conditions like limits on assets under management and the number of investors.
• European Union: Where wealth managers are regulated under the Markets in Financial Instruments Directive (MiFID II), requiring compliance with transparency, client protection, and high standards of professional conduct. Wealth managers must obtain the necessary authorisations and maintain compliance with each member state's regulatory framework.
• Popular Offshore financial centres, including:

• Cayman Islands: Where wealth managers must either obtain a Securities Investment Business Licence or register as a Registered Person with the Cayman Islands Monetary Authority (CIMA) under the Securities Investment Business Law (SIBL). Following amendments in 2019, the category of 'Excluded Persons' was replaced by 'Registered Persons'. Wealth managers dealing with sophisticated or high-net-worth (wholesale) clients must register with CIMA as Registered Persons, ensuring compliance with local regulatory requirements.
• British Virgin Islands (BVI): Where wealth managers must secure a Securities Licence from the Financial Services Commission (FSC) under the Securities and Investment Business Act 2010, adhering to BVI's regulatory standards.
• Seychelles: Where wealth managers must obtain a Securities Licence from the Financial Services Authority (FSA) under the Securities Act 2007, ensuring adherence to Seychelles' regulatory requirements.
• Jersey: Where wealth managers must obtain a Fund Services Business (FSB) licence from the Jersey Financial Services Commission (JFSC) under the Financial Services (Jersey) Law 1998.
• Guernsey: Where wealth managers must secure a licence from the Guernsey Financial Services Commission (GFSC) under the Protection of Investors (Bailiwick of Guernsey) Law, 1987.
• Isle of Man: Where wealth managers must obtain a licence from the Isle of Man Financial Services Authority (IOMFSA) under the Financial Services Act 2008.
• Hong Kong: Where wealth managers are required to be licensed by the Securities and Futures Commission (SFC) under the Securities and Futures Ordinance (SFO).
• Bermuda: Where wealth managers need a licence from the Bermuda Monetary Authority (BMA) under the Investment Business Act 2003.
• Mauritius: Where wealth managers must secure a licence from the Financial Services Commission (FSC) under the Securities Act 2005.

 

What Types of Wealth Managers Do We Support?

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

• Private Wealth Managers that focus on managing the wealth of high-net-worth individuals and families.
• Retail Wealth Managers that provide services to retail clients, adhering to stringent compliance requirements to protect client interests.
• Institutional Wealth Managers that serve institutional clients such as pension funds, insurance companies, and endowments.
• Boutique Wealth Managers that are smaller, specialised wealth management firms focusing on niche markets.
• Family Offices that manage wealth for single or multiple families.
• Robo-Advisors that offer automated investment advice and portfolio management.
• Cross-Border Investment and Tax Planning Advisors who specialise in advising on cross-border investments and tax planning.
• ESG-Focused Wealth Managers who integrate Environmental, Social, and Governance (ESG) factors into their investment strategies.

 

 

Wealth Managers’ Compliance Advisory

Our focus areas include:

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

 

 

Reporting and Regulatory Liaison Solutions for Wealth Managers’ Compliance

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

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

• Wealth Managers' Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable wealth managers' 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 wealth management 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 wealth managers' 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 wealth managers' 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 wealth managers' 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 wealth managers.
• 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 wealth managers' 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.
• Wealth Managers' 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 wealth managers' compliance obligations, including wealth managers' 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.

• Product-specific compliance requirements: We can also help you manage different product-specific areas of wealth management compliance, such as:

  • Investment advisory compliance and regulations
  • Compliance with financial planning standards
  • Regulatory requirements for retirement planning
  • Asset management compliance
  • Regulatory reporting and compliance assurance obligations under wealth managers' licensing requirements and regulations
  • Investment product suitability requirements

 

Wealth Managers’ 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 wealth management 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 wealth managers' compliance obligations, including wealth managers' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable wealth management 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 wealth managers' 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 wealth managers 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 wealth managers 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 wealth managers 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 Wealth Managers’ 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 wealth managers' compliance obligations.

We go beyond merely quoting wealth management 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 the wealth managers' compliance requirements include:

Regulatory Compliance and Licensing Controls

• Compliance Management: Wealth management specialists should have robust compliance management systems to adhere to various regulations governing investment advice and portfolio management.
• Capital Adequacy: Estate planners are expected to maintain sufficient capital levels to cover operational risks, especially in jurisdictions requiring minimum capital adequacy.
• Financial Auditing: Asset managers should conduct regular financial audits to ensure financial accuracy and compliance with fiduciary duties.
• Cross-Border Application of Regulations: Wealth management specialists are expected to comply with regulations when managing assets across borders, particularly in jurisdictions like the EU.
• ESG Compliance and Reporting: With the growing importance of Environmental, Social, and Governance (ESG) factors, wealth management specialists should establish controls to ensure compliance with ESG reporting requirements.

 

Operational Oversight Controls

• Outsourcing Oversight: Estate planners should maintain oversight over outsourced functions, such as custody services, to ensure they meet regulatory standards.
• Risk Management: Asset managers are expected to have frameworks to manage investment, operational, and compliance risks.
• Governance Arrangements: Wealth management specialists should have effective governance structures for decision-making and overseeing fiduciary responsibilities.
• Senior Management Accountability: Senior managers are expected to be accountable for upholding ethical standards and regulatory compliance.
• Operational Resilience: Wealth management specialists should have continuity plans for critical operations, including investment advisory and client communication.
• Technology Risk Management: Asset managers should manage technology risks, protecting client information and ensuring service continuity.
• Client Profiling and Suitability Assessments: Wealth management specialists are expected to implement robust processes for client profiling, ensuring investment strategies are tailored to individual client needs.

 

Market Integrity and Transparency Controls

• Market Conduct Standards: Wealth management specialists should ensure ethical conduct and adherence to market regulations.
• Fair Dealing Principles: Estate planners should treat clients fairly, with transparent advisory services and fee structures.
• Conduct and Disclosure Standards: Asset managers are expected to maintain high standards for client disclosures regarding investment strategies, risks, and fees.
• Service Provision Standards: Wealth management specialists should provide services efficiently, honestly, and in the client's best interest.
• Client Asset Protection: Estate planners are expected to have safeguards for client assets, including segregation of funds.
• Transparency in Fee Structures: Wealth management specialists should ensure clear communication of fee structures to build trust with clients.

 

Resource Management Controls

• Resource Adequacy: Asset managers should have sufficient resources for effective operation and compliance with regulatory obligations.
• Professional Competence: Wealth management specialists are expected to ensure staff, especially investment advisors, are competent and adhere to professional standards.
• Advisor and Representative Competence: Advisers and representatives must be adequately trained and qualified to provide investment advice.
• Continuous Professional Development in Emerging Areas: Wealth management specialists should emphasise the importance of continuous professional development for advisors, particularly in emerging areas such as digital assets, fintech innovations, and sustainable investing.

Investment Product Suitability and Lifecycle Management Controls

• Product Suitability Assessments: Wealth management specialists should implement robust processes to assess the suitability of investment products for different client segments. This includes evaluating risk tolerance, investment objectives, and financial situations.
• Lifecycle Management of Investment Products: Wealth management specialists are expected to regularly review and monitor investment products to ensure they remain suitable and compliant with regulatory requirements throughout their lifecycle.
• Product Development and Approval Processes: Wealth management specialists should establish clear processes for the development, approval, and launch of new investment products. These processes should ensure that products meet regulatory standards and are suitable for target clients.
• Risk Assessment of Investment Products: Wealth management specialists are expected to conduct thorough risk assessments for all investment products. This includes stress testing and scenario analysis to identify potential risks and their impact on clients.
• Disclosure and Communication: Wealth management specialists should provide clients with clear and comprehensive information about investment products, including risks, fees, and performance expectations.
• Compliance with Regulatory Standards for Product Suitability: Wealth management specialists are expected to ensure that all investment products meet regulatory standards for suitability, including compliance with MiFID II, SEC regulations, and other relevant standards.
• Client Feedback and Product Adjustments: Wealth management specialists should actively seek and incorporate client feedback to make necessary adjustments to investment products, ensuring they continue to meet client needs and regulatory requirements.
• Training and Competence in Product Suitability: Wealth management specialists are expected to ensure that all advisors and relevant staff are adequately trained and competent in assessing product suitability and managing the lifecycle of investment products.

 

Reporting Controls

• Comprehensive Transaction Reporting: Wealth management specialists should have detailed reporting of client transactions and portfolio performance.
• Regulatory Reporting: Asset managers are expected to regularly report to authorities on compliance, client asset management, and advisory services.
• Record-Keeping: Wealth management specialists should maintain accurate records of client advisories, investment decisions, and transactions.
• Client Performance Reporting: Estate planners are expected to provide clear performance insights to clients.

 

Transactional Controls

• Best Execution Oversight: Asset managers should ensure that client transactions are executed in their best interest, considering costs, speed, and likelihood of execution.
• Authorisation and Verification Procedures: Wealth management specialists should verify client authorisation for portfolio transactions and ensure they align with the investment strategy and client objectives.
• Conflict of Interest Management: Estate planners are expected to identify and manage conflicts of interest in investment recommendations and portfolio management.
• Monitoring of Leveraged and Complex Transactions: Asset managers should oversee investment strategies involving leverage or complex products to ensure they align with client risk profiles and objectives.
• Periodic Review and Reconciliation: Wealth management specialists are expected to regularly review client portfolios to ensure alignment with investment objectives and strategy.
• Digital Transaction Security: Asset managers should implement stringent security measures to protect digital transactions against fraud and cyber threats.

 

Licensing and Registration Solutions for Wealth Managers

• Financial Licensing Application Support: We provide comprehensive support for a wide range of wealth managers’ licensing applications, including:

• Australian Financial Services Licence (AFSL): We assist wealth managers dealing with retail clients in obtaining an AFSL from ASIC under the Corporations Act 2001. For non-retail providers and wealth management providers that are exempt from the local wealth managers' licensing requirements, we offer guidance on operating under an AFSL Exemption while ensuring compliance with AML/CTF Act 2006 and AML/CTF obligations supervised by AUSTRAC.  For more information about our solutions to help you meet the Australian wealth managers' licensing requirements, please visit our ASFL page for wealth managers.
• Managed Investment Scheme (MIS) Manager Licence in New Zealand: Our team supports wealth managers in obtaining an MIS Manager Licence from the FMA under the Financial Markets Conduct Act 2013. For wholesale clients, we provide Financial Service Providers Register (FSPR) registration services and ensure compliance with AML/CFT regulations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, supervised by the FMA. For more information about our solutions to help you meet the New Zealand wealth managers' licensing requirements, please visit our FMA Licence page for wealth managers.
• FCA Authorisation in the United Kingdom: We help wealth managers secure FCA authorisation under the Financial Services and Markets Act 2000, ensuring compliance for both retail and professional clients with specific regulatory requirements. For non-retail clients, we provide compliance solutions under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, supervised by the FCA. For more information about our solutions to help you meet the UK wealth managers' FCA authorisation requirements, please visit our FCA Authorisation page for wealth managers.
• Investment Adviser Registration in the United States: We assist wealth managers with registration as Investment Advisers with the SEC or state securities authorities under the Investment Advisers Act of 1940, providing tailored solutions for retail and institutional client services. For non-retail clients, we ensure adherence to AML regulations under the Bank Secrecy Act, supervised by FinCEN.
• Capital Markets Services Licence (CMSL) in Singapore: Our experts guide wealth managers through the CMSL application process with MAS under the Securities and Futures Act. We also offer compliance solutions for wealth managers serving accredited or institutional clients, including adherence to MAS guidelines and AML/CFT regulations under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, supervised by MAS.
• MiFID II Compliance in the European Union: We provide comprehensive support for wealth managers seeking authorisation under MiFID II, ensuring compliance with transparency, client protection, and high standards of professional conduct. Our services include tailored solutions for navigating each EU member state's regulatory framework and AML/CFT requirements under the Fourth Anti-Money Laundering Directive, supervised by national competent authorities.
• Securities Business Licence in the Cayman Islands: We assist wealth managers in obtaining a Securities Business Licence from CIMA under the Securities Investment Business Law, ensuring compliance with local wealth management regulations. For non-retail clients, we offer AML/CFT solutions under the Anti-Money Laundering Regulations, supervised by CIMA.
• Securities Licence in the British Virgin Islands (BVI): Our team supports wealth managers in securing a Securities Licence from the FSC under the Securities and Investment Business Act 2010. For non-retail clients, we provide compliance solutions under the Anti-Money Laundering and Terrorist Financing Code of Practice, supervised by the FSC.
• Securities Licence in Seychelles: We help wealth managers obtain a Securities Licence from the FSA under the Securities Act 2007, ensuring regulatory compliance. Our services extend to AML/CFT solutions under the Anti-Money Laundering Act, supervised by the FSA, for wealth managers offering services to non-retail clients.
• Fund Services Business (FSB) Licence in Jersey: We guide wealth managers through the FSB licence application process with the JFSC under the Financial Services (Jersey) Law 1998, including compliance support for non-retail services. We also ensure adherence to AML/CFT regulations under the Money Laundering (Jersey) Order, supervised by the JFSC.
• Licence from the Guernsey Financial Services Commission (GFSC): Our experts assist wealth managers in securing a licence under the Protection of Investors (Bailiwick of Guernsey) Law, 1987, helping them comply with the local wealth managers' licensing requirements. We ensure adherence to AML/CFT regulations under the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, supervised by the GFSC.
• Licence from the Isle of Man Financial Services Authority (IOMFSA): We support wealth managers in obtaining a licence under the Financial Services Act 2008, offering compliance services for non-retail client operations. We also ensure compliance with AML/CFT regulations under the Anti-Money Laundering and Countering the Financing of Terrorism Code, supervised by the IOMFSA.
• Securities and Futures Commission (SFC) Licence in Hong Kong: We assist wealth managers in obtaining a licence under the Securities and Futures Ordinance (SFO), providing regulatory compliance solutions for both retail and non-retail services. For non-retail clients, we ensure compliance with AML/CFT regulations under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, supervised by the SFC.
• Licence from the Bermuda Monetary Authority (BMA): Our team helps wealth managers secure a licence under the Investment Business Act 2003, ensuring compliance for services to both retail and non-retail clients. We provide AML/CFT solutions under the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations, supervised by the BMA.
• Licence from the Financial Services Commission (FSC) in Mauritius: We assist wealth managers in obtaining a licence under the Securities Act 2005, providing additional AML/CFT solutions for services to non-retail clients under the Financial Intelligence and Anti-Money Laundering Act, supervised by the FSC.
• Other jurisdictions.

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

 

 Policies and Procedures for Wealth Managers’ Compliance Management

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective wealth managers' compliance management.
• Effective Procedures for Wealth Managers' 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 wealth managers' 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
• Digital Advisory Compliance 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
• Internal Control Testing Methodologies
• Risk Registers and specialised risk registers like Health and Safety Risk Registers
• Cybersecurity Risk Management Policies
• Whistleblowing 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

• Client Communication Policies
• Marketing and Advertising Policy
• Staff Dealing and Insider Trading Policy
• Robo-Advice Data Management Policies (if applicable)
• Fair Dealing Policy
• Investment Product Suitability  (mostly applicable to wealth managers offering services to non-retail investors, but also can be applicable to wealth managers that detail retail investors. , depending on the specific licensing type and jurisdiction).

 

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 wealth managers 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 wealth management regulations, applying wealth managers' 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 wealth managers' 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 the new AML trends, red flags, typologies, and AML/CFT requirements for wealth managers. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented wealth managers' compliance, capacity planning, and resource allocation, covering:

• Wealth management 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.
• Wealth managers' 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.

 

Wealth Managers and AML/CTF Compliance

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

 

Wealth Managers’ 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 wealth managers, including:

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

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting wealth managers 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 wealth managers' compliance with applicable regulatory reporting standards and reporting requirements.
• Record Availability and Inspection Readiness:  Wealth management 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.
• Cybersecurity Measures for Client Data Protection: Advising wealth managers on the regulatory compliance aspects related to the implementation of specific cybersecurity measures for client data protection.

 

ISO Standards and Wealth Managers’ 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 wealth managers' 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 wealth managers' 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 wealth managers through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.