Case Study: Regulatory compliance assurance |
Abstract
A financial services firm required assurance that they were compliant with regulations relating to areas in which they operated.
Challenge
This engagement required Deloitte to provide assurance on the compliance policies and procedures in a financial services company. In a highly regulated industry such as financial services, it was necessary to focus on a variety of regulations including reporting to overseas regulatory bodies, the examination of anti-money laundering procedures and capital requirements planning.
We were also required to define how the reporting process requirements would be applied across a wide variety of locations where the company branches operated.
Approach
To ensure that regulatory reporting requirements were being met throughout the organisation we undertook analysis of processes and documentation across a number of key areas:
- Benchmarking of Anti-Money Laundering Procedures to the Criminal Justice Act, 1994
- Authorisations on a branch basis
- Reporting processes by location
- Review of communications with regulatory bodies
- Sample Testing anti-money laundering documentation
- Review of staff training records
- Sample testing of Capital adequacy reports
- Procedures regarding reporting to foreign regulatory bodies and benchmarking against relevant legislation
Solution
Through the assessment of operation and design of the many policies and procedures in place, we were able to provide the client with the required detail on their ability to meet compliance requirements and ensure the company was aware of their obligations in these areas:
- Benchmarks against industry best practice in meeting compliance requirements
- Checklists and guideline documentation to guide future initiatives in the areas examined
Findings included:
- The presence of internal controls to prevent money laundering
- Regular monitoring and updates of controls
- Education and training for all members of staff on money laundering compliance and detection procedures
- The controlled provision of access to internal records to assist with the internal reporting procedures
- The regular distribution of relevant compliance procedures and manuals to staff
- Documented procedures for prompt validation and notification of suspicions
- Co-operation and liaison with the relevant authorities (E.g. Garda Siochana and the Revenue Commissioners)
