Consultant, Joe French of Newgate Compliance, an Ocorian-owned, London-based compliance consultancy and hosted regulatory solutions provider for funds clients, stresses the importance of reviewing compliance controls as many workforces continue to work from home.
One major by-product of the global Covid-19 pandemic is that "working from home" has become widespread and almost an industry norm for many firms operating in the financial markets. The FCA has spoken around the importance of making sure that, going forward, office and working from home arrangements should be equivalent in terms of compliance controls and procedures.
As we enter the latest lockdown, Newgate is working with clients to ensure their policies, procedures and risk assessments have been updated to take into account these significant changes to working practices.
Although not intentional or malicious, distance working can create an "out of sight, out of mind" approach to key compliance policies and the challenge for senior managers and firms is how to monitor and control this risk.
If you are a senior manager or compliance officer at a regulated firm, there are some key areas which you need to be thinking of addressing as part of the new normal.
- Updating telephone recording policies.
- Updating communications policies and procedures with a particular focus on financial promotions.
- Increasing the monitoring of electronic and telephone communications.
Data protection and data security
- Undertaking data protection impact assessments to look at the risks posed both in the short and long term.
- Updating policies, procedures and monitoring around the different risks posed by home working.
- Making staff aware of the enhanced requirements around areas such as laptop or phone security, the use of personal devices and the storage of personal client data.
Market conduct controls
- Updating your market abuse risk assessment to address remote working risks.
- Updating policies and procedures around confidential or inside information.
- Updating PA dealing policies and circulating extra reminders to all employees around the approval process for personal account transactions.
Newgate's unique online compliance system, the GATEway©, is a comprehensive compliance management tool enabling a firm to undertake the compliance monitoring programme within a secure on-line infrastructure and fits perfectly into the working from home environment.
GATEway also allows a firm to monitor and track employee compliance filings, for example, personal account trading, gifts and benefits reporting and attestations. It will not only make the process more efficient but will enable your firm to evidence full details of any employee compliance filing, if required to do so at a later date.
Not only is GATEway a depositary holding all policies, registers, forms and procedures but it also has a library of articles and documents on a wide range of regulatory topics and issues.