Improvise, overcome and adapt your CMS to changing times

Michael Berman
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Michael Berman: Founder and CEO, Ncontracts, USA

Journal of Financial Compliance, 2022, vol. 5, issue 3, 248-256

Abstract: Compliance has unfairly earned a reputation for uncompromising rigidity, but the reality is that the compliance function is just as capable of and reliant on creative thinking and problem solving as any other department. But for this to happen, compliance needs the right resources and support — including a compliance management system (CMS) built to support improvisation and adaptability so that financial institutions can effectively overcome compliance challenges. From outside events such as the COVID-19 pandemic to internal goals such as growth, the operational environment of financial institution’s requires a distinct combination of flexibility and prescriptive institutional policies and procedures. This paper offers four building blocks for a compliance management system to achieve this balance: a risk management mindset, standardisation, policy and procedure management and resource prioritisation. It reviews recent enforcement actions to illustrate why these elements are essential to a CMS that can keep pace with environmental and regulatory change.

Keywords: Risk management; compliance; operational risk; compliance management; financial institutions; policy and procedure (search for similar items in EconPapers)
JEL-codes: E5 G2 K2 (search for similar items in EconPapers)
Date: 2022
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Persistent link: https://EconPapers.repec.org/RePEc:aza:jfc000:y:2022:v:5:i:3:p:248-256

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