The primary function of compliance is regarded as ensuring that a company complies with all the necessary regulations, however our approach puts just as much emphasis on doing the right thing for clients – ensuring the security of their assets and a high standard of service.
How my day begins
The various lockdowns over the last year have had me glued to my desk for most of the day, so I make sure I go for a run or an interval training session early in the morning. I’m no fitness fanatic, but you have to look after yourself in these trying times!
My workday starts around 8.30am with a good hour or so of regulatory intelligence, analysing the wide range of daily emails, alerts and news reports that I receive from various resources. These include, of course, our regulator the Financial Conduct Authority (FCA) but also the UK government, media outlets and industry experts.
This is time well spent, it alerts me to upstream developments which may necessitate changes to the way we do things – keeping us ahead of the curve.
Financial crime on my mind
Not as suspicious as it sounds – my role as the Money Laundering Reporting Officer (MLRO) at Netwealth means I must stay abreast of the financial crime threat landscape and constantly review our defences. There is never a dull moment in this space as individuals are continuously finding new and ever more ingenious methods for committing financial crime.
My morning might include a review of financial crime alerts, which highlight any suspicious activity flagged during client onboarding, transactions or communications. Thankfully Netwealth’s controls framework is grounded in our proprietary technology, which is inherently agile and therefore extremely robust, so it is rare that my investigations reveal any actual attempted wrongdoing.
Nevertheless, our unique combination of technology and skilled human oversight provides me with reassurance and should give comfort to our clients that their assets are in safe hands.
Over the last year or so the FCA and the much of the wider industry has been attempting to address the proliferation of investments scams, particularly targeting vulnerable people during the COVID-19 pandemic. This has been an area of focus for me, resulting in updates to our vulnerability policy and processes to reflect evolving industry best practice.
There is, however, no substitute for healthy suspicion, particularly when an investment opportunity sounds too good to be true.
Evolving the ‘Business Protection Unit’
In the late 1990s when I first started in financial services the compliance function was still in its infancy but was often jokingly referred to as the ‘Business Prevention Unit’, because a good deal of its perceived activity involved stopping new business. This attitude has changed over the years and now the role of compliance is seen as providing essential protection for the firm, our staff and most importantly, our clients.
During an average day I will engage with many of our departments and fellow members of the senior management team, providing advice and clarification on regulatory requirements, and helping to guide our strategy and approach. Regular tasks include approving our marketing materials and documentation, overseeing our governance framework and implementing a comprehensive programme of compliance monitoring.
Periodically I will review and adapt our policies, assess our exposure to a range of risks and work with the business to test and enhance our systems and controls.
We are always developing our technology to improve the client experience, so I may find myself joining a project group with our engineering team, considering for example the compliance impacts of a slick new feature. I might jump on a call with the client advisory or client service teams to discuss a specific investor scenario or a process where we could enhance efficiency.
No two days are ever the same and I enjoy engaging with our people – it keeps me informed, keeps me thinking and always keeps me on my toes.
"Compliance is all about finding the right way to do the right thing"
My afternoons often include webinars or virtual meetings with discussion groups and my peer heads of compliance at other firms, where we debate FCA and European publications and share best practice. I may work on a direct response to an FCA consultation or contribute to an industry response via our trade body PIMFA (Personal Investment Management & Financial Advice Association).
This helps to ensure that regulation is measured, proportionate and effective. Compliance is all about finding the right way to do the right thing, aiming not just to interpret and implement regulation, but also to influence its progress.
Train to maintain (and to improve)
One of the lesser-known duties of the compliance function is to oversee fitness and propriety, which means ensuring that our staff are properly trained, have the right knowledge and skills, maintain awareness of their regulatory duties and are assessed as fit and proper to perform their roles.
While we use external providers for some of our staff training, I like to do as much of this as possible myself, building my own courses and delivering them face-to-face (or more recently face-to-screen). The key here is to take what can be a somewhat dry subject matter and make it relevant, engaging and where possible, even a bit of fun.
At Netwealth everyone strives to be the best at what they do, so when I want to run a session on a new regulation, internal development, or even a simple refresher on the basics of compliance, my audience will invariably be eager and inquisitive.
Under the current restrictions it is so important to look after both one’s physical and mental health, taking time to wind down, reflect on the day and transition from work to home life. I live quite far outside of London, so the commute home used to provide this, at least when I wasn’t completely absorbed in a sci-fi novel (or regulatory publication).
These days I make sure I have 20 minutes of quiet time for meditation each evening and that seems to do the trick. However, when my ‘zen’ period is up it’s straight to the den for playtime with my two extremely energetic preschool sons. To be honest it is a full workout just keeping up with them!
Please remember that when investing your capital is at risk.