Aspect Advisory

Regulatory handbook review

Overview

In this very informative project, Aspect Advisory was tasked with reviewing a multi-national corporate bank’s regulatory framework aimed at informing its line managers on the bank’s code of conduct, latest governance trends in anti-money laundering, sanctions and anti-bribery and anti-corruption. The bank had complete compliance handbooks that needed Aspect Advisory’s assurance that they were fully compliant with the latest regulations.

Solution

Aspect Advisory undertook a massive benchmarking exercise where we cross examined contents of the handbooks with up-to-date amendments in laws and regulations as well as researched recent Acts that were passed after the handbooks had been drafted. We also leveraged our vast experience and relationships with comparable financial institutions to benchmark the trending formats and information related to code of conduct, sanctions, anti-bribery and anti-corruption and anti-money laundering.

Result

We produced updated handbooks which incorporated the latest legislation, in particular; Market Abuse Regulation, Foreign corrupt practices act, UK bribery Act, OECD guidelines on anti-bribery, updated the sanctions list based on the list-based sanctions regime, UK sanctions list and addressed issues omitted in the anti-money laundering and counter-terrorist financing by making appropriate reference to the Financial Action Task Force (FATF) and the Bank Secrecy Act. The benchmarking marking exercise allowed us to amend the handbooks by incorporating detailed reviews on Environmental, Social and Governance, as well as the effect of COVID-19 pandemic on compliance

Business Area

  • Strategy, project management, mergers and acquisition

Skill sets

  •  Research, writing, interpretation of legal texts

Insights

The coronavirus pandemic has increased risks and complicated compliance efforts on a variety of fronts. The major issues that compliance is faced with during the pandemic are as follows:

  • Budget cuts- One of major issue arising from the pandemic is the stretching of resources, which in most cases, leaves less resources for compliance matters with the company. Compliance departments might face cuts due to the economic downturn resulting from the pandemic, raising concerns about the potential for mistakes or for unethical behaviour to go undetected.
  • Remote working-travel restrictions complicate the Bank’s ability to monitor and prevent bribery and other misconduct.
  • PPE-compliance teams are vetting new vendors and suppliers in regard to PPE. This is to ensure that the Covid-19 protocols within the company are compliant with government guidelines and regulations.