The latest update to the FCA’s webpage on Covid-19 reiterates the FCA’s position that firms should be taking reasonable steps to maintain compliance. Cases of Covid-19 are growing internationally and the majority of firms will be impacted as financial services firms are connected globally.
During this time of uncertainty as firms rely on remote or staggered working arrangements, the Compliance Officer, who hitherto may have been sitting in close proximity to colleagues, is likely to also be working remotely. So how does the Compliance Officer obtain comfort that the firm’s front line business activities remain In Compliance?
We think, just as before. The purpose of embedding compliance requirements into process and monitoring through management information, is that, at all times, even in a crisis, the Compliance Officer can have confidence in the compliant design of business processes and the reporting infrastructure to show that compliance continues operationally. We believe, the risks to compliance lie where there has been a need to amend established processes and reduce management information.
It is likely that the FCA has chosen the phrase “reasonable steps” deliberately. It is not a standard of perfection or total compliance. It is the relative standard expected of all senior managers of financial services firms at all times, that the FCA can assess against the circumstances in existence at the time.
Where those “reasonable steps” require additional assistance and / or remote compliance support, Ellis Wilson can help your business stay In Compliance. Contact Jon or Kim for a “virtual meeting” to find out more.
Click here to read the Top 10 areas we think investment managers and advisers are most sensitive to Covid-19 non-compliance because of the speed with which businesses have had to respond.