1. 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

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

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

4. 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:

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

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

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

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

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

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

11. Concerns / Observations
Directors contradicting the Compliance Officer Report.

12. Concerns / Observations
Incorrect information, discrepancies and misinformation.

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

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

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

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

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

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

19. Conclusions
Questions / Comments