Create a Culture of Accountability – this is not the same as laying blame at the door of someone if it seems that there has been an issue.  That’ll definitely have the opposite effect! 

A culture of accountability is about making sure there is clear guidance about what people need to do. Are there clear expectations?  Do managers lead by example?  Is there sufficient training?  Are employees told how they can improve?  Making sure the answers to these questions are ‘Yes’ will lead to compliance being a shared responsibility – not just something for a compliance team, the COLP or a couple of Partners.

Creating Great Communication – it’s not just sending instructions, it’s about making sure your message is clear, consistent and reaches the people that need to hear it. 

Emails with compliance updates can end up being lengthy and confusing, or just another email in a deluge of internal and external emails.  Emails can’t always be avoided, but we all know how easy it is to leave internal emails ‘for later’ or file them away without really considering them.

Communicating change can be at departmental meetings (make sure there are minutes), whole staff meetings, via the firm’s intranet, or by email.  It’s about looking for ways to get the right information to the right people in the right timeframe. 

Good communication from management also encourages good communication from employees – essential if concerns about breaches, or questions about procedure, are going to be addressed effectively. 

Investment in Technology – technology can make a big difference to having effective compliance, and save precious time for employees and clients. 

Technology can cover bigger items such as case management systems, which all have really useful ways of managing information and checking compliance.  It can also cover specific Regulatory Technology (RegTech) products to help with things including checking ID, for sanctions, or whether a client is a PEP.

It can feel daunting for managers who are less confident in technology generally, but there are lots of sources of help and advice.  

A new system, or an upgrade or change, may become part of a longer term plan to be budgeted for.  That is OK, but it starts with good managers considering the possibility and making informed decisions.

Encouraging Training and Development – it’s not just about making sure all the compulsory training has been organised. 

Good managers will lead by example, making sure they complete the training and encouraging others to do the same.  The tone of messaging about training can make a huge difference.  A message that “this is a giant pain in the neck so let’s just get it over with, even though we only did it a year ago” is not effective at making sure people complete their training!

Managers that see the benefit of making sure everyone understands what is needed and why, in a way that is relevant to their role, will have a much better chance of making sure their firm remains compliant and reputable.

Good managers will also make sure employees have the time to carry out the training – not just compulsory training, but effective, useful training that counts towards the obligations of continuing competence and has been considered as part of a training plan. 

It doesn’t have to always be one annual, formal training course. Although some training has to take place annually, with the content and participation recorded, effective training can be delivered with a ‘drip feed’ approach.  Compliance requirements change so much, so regularly, that an update will be more effective if delivered at the time, rather than waiting for an annual training event.