SUMMARY
The client, a major player in the fund industry, contacted Avantage Reply seeking assistance to its Chief Compliance Officer. Indeed, as part of a fast-changing environment and due to new activities and projects being launched, the client needed Avantage Reply to bring expertise in covering all compliance topics of its "Business as Usual" activities as well as to assist and advise on its new Fund Dealing projects.
CUSTOMER GOALS
Our client was seeking to strengthen its BAU in the fields of Financial Security, Market Integrity, Corporate Compliance (Policies and Procedures, Complaints, Ethics, Conflict of Interest, Anti-Fraud and Corruption), Training, Regulatory Updates and Regulatory Reports. There was also a need to assess and map compliance risks as well as to implement new measures such as Distribution Oversight, oversight of Service Providers and a new Transaction Monitoring activity linked to the recent and growing Fund Dealing activities. In addition, one of the most urgent needs was to tackle the audit recommendations from the latest audit report as the client had the obligation to give proof of implementation within an aggressive deadline.
CHALLENGES
The diversity of the topics, the fast-changing environment, the understaffing and the aggressive deadline made this project a true challenge to overcome for Avantage Reply's Compliance Practice.
SOLUTION
To achieve the goals, an experienced consultant from Avantage Reply's team delivered the following tasks:
• Drafting and implementing new procedures as well as reviewing and improving current ones• Rewriting and refining the client's AML Handbook• Improving and implementing the best execution and selection policy following market integrity guides• Reviewing the current risk mapping and compliance risk involved in the new activities• Guiding the compliance department in its role with the new activities• Advising during the Steering Committees• Accompanying the client in the implementation of the new transaction monitoring activity• Formalizing the oversight activities• Implementing the audit recommendations within deadlines• Presenting compliance activities, KPIs, results and recent topics to the Executive Committee and Board of Directors• Drafting and implementing the Compliance Control Plan• Following up and supervising the BAU performed by the compliance officers in charge of the financial security and performing second line of defense controls• Carrying out reporting to the local regulator• Finding a solution to have accurate transaction reporting to the regulator for ETF dealing with fractional shares and its need to reflect the positions with decimals