Checklist on policy, procedures and controls (Compliance Manual)

The document titled 'Checklist on policy, procedures and controls (Compliance Manual)' is a comprehensive guide for financial institutions and funds to ensure compliance with corporate governance, risk management, and operational control requirements. The document covers various aspects of compliance, including the establishment of a management structure, oversight of senior management, supervision of staff members, performance evaluation, and training.

 

The document begins with a section on corporate governance, which emphasizes the importance of establishing a management structure that includes clear roles, responsibilities, accountability, and reporting lines for senior management. It also highlights the need for the board of directors to oversee the appointment and performance of senior management, as well as the establishment of policies to ensure their access to regular training.

 

The next section focuses on risk management, emphasizing the need for written policies and control procedures to identify, monitor, and control risks associated with business activities. It also highlights the importance of regular reviews and stress testing to ensure the adequacy of risk management measures.

 

The document then addresses various functions, including key business lines, operational control and review, finance and accounting, information technology, compliance, and anti-money laundering and counter-terrorism financing. For each function, it asks whether there are written policies and control procedures in place and how often they will be reviewed and updated.

 

The document also covers areas such as client onboarding, conflicts of interest, safeguarding of client assets, compliance, complaint handling, and anti-money laundering and counter-terrorism financing. It asks whether there are written policies and control procedures in place to address these areas and ensure compliance with relevant legal and regulatory requirements.

 

Finally, the document includes a section on personnel and training, emphasizing the importance of communicating operational and control policies and procedures to new recruits, providing ongoing training, and ensuring staff members are aware of their obligations regarding staff dealing.

 

Overall, the document provides a comprehensive checklist for financial institutions and funds to ensure compliance with policy, procedures, and controls related to corporate governance, risk management, and operational control.

How to use this document?

1. Establish a management structure that includes clear roles, responsibilities, accountability, and reporting lines for senior management.

2. Ensure the board of directors oversees the appointment and performance of senior management.

3. Establish policies to ensure senior management has access to regular training.

4. Develop written policies and control procedures to identify, monitor, and control risks associated with business activities.

5. Conduct regular reviews and stress testing to ensure the adequacy of risk management measures.

6. Develop written policies and control procedures for key business lines, operational control and review, finance and accounting, information technology, compliance, and anti-money laundering and counter-terrorism financing.

7. Review and update these policies and control procedures regularly.

8. Develop written policies and control procedures for client onboarding, conflicts of interest, safeguarding of client assets, compliance, complaint handling, and anti-money laundering and counter-terrorism financing.

9. Ensure staff members are aware of their obligations regarding staff dealing.

10. Provide ongoing training to staff members to ensure they possess or acquire appropriate and practical experience.

11. Communicate operational and control policies and procedures to new recruits.

12. Distribute updated policies and procedures to staff members and make them accessible at all times.

13. Communicate any changes to policies and procedures to staff members.

14. Obtain written consent before dealing in securities or futures contracts for another licensed or registered person's staff member.

15. Provide adequate training to staff members both initially and on an ongoing basis.

16. Ensure staff members possess or acquire appropriate and practical experience through on-the-job training and structured courses.