Regulatory
Building a Compliance Programme That Survives Review
Regulators do not assess intentions. They assess records.
A compliance programme is judged on evidence: documented policy, documented training, documented escalation, and documented consequence. A programme that functions informally but leaves no record will be treated as absent.
The second test is proportionality. Controls must reflect the business as it actually operates, including the parts that grew faster than the policy that governs them.
The third is responsiveness. A single unremediated finding, carried across review cycles, does more damage than the original deficiency.
We recommend an annual internal review conducted against the questions a regulator would ask, with findings recorded and closed on a dated register.
This article is general commentary and does not constitute legal advice. No attorney-client relationship arises from reading it. Advice on a specific matter should be sought before acting.