As the pandemic and subsequent lockdowns forced businesses to fundamentally alter the way they operated, Business Continuity Plans (“BCPs”) were invoked, and firms strived to adapt. Lockdowns and social distancing requirements resulted in the unavoidable challenge of adopting a work from home model and for many, with remote working came a feeling of isolation and a loosening of control.
Although some businesses are beginning to return to their offices, it is on a restricted basis as the uncertainty of a permanent ‘return to normal’ continues. Now that the dust has settled somewhat, we urge you to take the opportunity to review your control framework, considering the lessons learnt from maintaining effective compliance control whilst working on a remote basis.
Remember, after every financial crisis there has been some form of regulatory response so now is the time to ask yourself: have your controls been robust enough to deal with the new and increased risks?
The first step in this process is to evaluate your current control environment by:
- Reviewing your risk registers and making sure they are up to date
- Speaking with senior management and discussing key risks (new and old) and new challenges
- Assessing whether risk levels have changed and if current controls remain realistic and robust
- Identifying areas where BCP implementation has not been as effective as anticipated
Once you have completed this evaluation, the list we have prepared in our download 'Reviewing your Compliance Controls Post Lockdown' may help you to identify some additional risks to incorporate into your control framework or to help update the existing risks you have previously identified, enhancing controls already in place. The areas included are:
- Access to Compliance
- Anti-Money Laundering ("AML") & Financial Crime
- Regulatory Reporting
- Treating Customers Fairly
- Market Integrity
- Operational & Financial Resilience
Download this article now for full details.