A sound compliance framework is an essential component for any legal entity, however particularly for those licensed entities in terms of their regulatory obligation as well as subject persons in view of their AML and CFT obligations.
Fostering a compliance culture with an organization is the first step to ensuring adherence to compliance obligations and proper enforcement by senior management. The development and regular review of a Compliance Plan allows a business to remain reactive to unforeseen changes.
Preventive rather than Reactive
As mentioned, a sense of urgency leads to rapid change. How can we replicate that sense of urgency to shift our business continuity approach to being preventative, rather than reactive?
- Reassess your company’s risk profile in light of the emerging pressures and resulting compliance failures;
- Re-enforce and restructure a compliance culture, including proper understanding and adherence to data privacy rules;
- Create a one to three year plan focused on enhancing the company’s compliance program;
- Set reasonable targets which take into account the business resources, limitations, customer base, and suppliers;
- Refresh compliance training addressing the compliance failures which took place during the pandemic, together with a plan on how to address, resolve and mitigate these new risks within the company;
- Ensure all employees and relevant third parties are involved, and have proper access to the relevant compliance material, policies, and procedures;
- Address linguistic and cross-jurisdictional barriers, such as closure of registries, lockdowns, and the consequential difficulties arising from these unprecedented times;
- Document your root cause analysis, system improvements, policy updates, training refreshers, and all that is being done by the company as a rectification process;
- Create an audit trail as this will come in handy during regulatory offsite inspections as well so even more important; and
- Balance reward of sale with an effective compliance culture and include a compliance measurement into job performance matrices.
BDO is here to help!
Our Compliance Advisory department can help you with setting up the necessary compliance programs, a vital aspect of any business continuity plans.
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