Presented by Simone E. Martin, MBA, FICA

Slides:

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Presentation transcript:

Compliance Officer Reports Key Issues & Considerations BVI Association of Compliance Officers Presented by Simone E. Martin, MBA, FICA Deputy Director, Fiduciary Services BVI Financial Services Commission

Overview Components of the Compliance Officer Report A section by section review. Useful considerations and other points. Concerns and Observations 2

Overview Beyond the Compliance Officer Report. Conclusions What else should Compliance Officers be minded of? Conclusions 3

Components of the Compliance Officer Report A Compliance Officer Report should be submitted in the form and context of section 48 of the Code. Section 48 of the Code provides that, “The report submitted by the compliance officer shall at a minimum contain the following:

Components of the Compliance Officer Report Section 48(1)(a) the training register

Components of the Compliance Officer Report Section 48(1)(b) a list of any legislative breaches, along with the remedial action taken.

Components of the Compliance Officer Report Section 48(1)(c) total number of SARs filed

Components of the Compliance Officer Report Section 48(1)(d) a list of significant complaints made by customers

Components of the Compliance Officer Report Section 48(1)(e) significant breakdowns in the internal control structure

Concerns / Observations Breaches reported and no comments on what remedial action is to be taken.

Concerns / Observations Directors contradicting the Compliance Officer Report.

Concerns / Observations Incorrect information, discrepancies and misinformation.

Concerns / Observations Subjective comments and conclusions that are not supported by other filings and/or findings.

Beyond the Compliance Officer Report Other statutory obligations. immediately reporting to the Commission any serious compliance breach maintenance of a Register of Compliance breaches

Beyond the Compliance Officer Report Ensure the licensee meets its reporting obligations.

Beyond the Compliance Officer Report Identify, measure and assess the compliance risks associated with the licensee’s business.

Conclusions Take away points for Compliance Officers:- Ensure quality reports with relevant information

Conclusions Obligations of a Compliance Officer extend far beyond the Compliance Officer Report.

Conclusions Questions / Comments