OK, So Why Should I Need A Compliance Manual?
For any Compliance Officer or SMF16 who has been in the UK financial services industry for any more than a year, this document is important.
Critically they will know that one of the first documents that they, as well as all staff, have to read and attest to having done so, is the Company Compliance Manual.
Although this is not a regulatory requirement …
it is becoming a regulatory expectation!
There are a number of elements that the regulators not only expect to be documented, but also somewhere that explains the rationale behind the way company’s manager their risks. This would clearly be best summarised in a regulatory Operational or Compliance Manual.
The Regulator expects a firm to have a personalised and firm-specific compliance operating procedures manual pertinent to the firm and embedded within its processes and culture.
Most on-line and centrally maintained manuals offered by some consultancies are considered NOT to be personalised, firm specific OR relevant enough to the individual firm.
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An additional function is where the firm can articulate how they expect the staff to operate and the standards that they are expected to adhere to.
But what do I put in it?
Often Compliance Manuals can be used to document the sales process for adviser’s to follow including, for example, transaction only clients.
There has to be clear distinction for specific procedures and, for example when to assess a client for appropriateness when they refuse to provide sufficient details for suitability.
We do not suggest you fill your Compliance Manual with just processes as it is a valuable place to store certain high level explanations of policies such as the Data Protection Act, Bribery Act, Outsourcing Policy and Whistleblowing protocols.
Additionally this invaluable document can be used to point to other company documents such as policies and forms or other constantly updated items such as the Anti-money Laundering and Terrorist Financing procedures or even areas such as your Approved Persons Policy or possibly additional changes from Euroland.