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Core Module 2 – Identifying and Reporting Compliance Risk

Question 1.

Your head of compliance has asked you to review the way in which the firm deals with breaches, including breaches of internal policies and procedures in addition to regulatory breaches. The current requirement is for all departments to keep their own ‘breaches register’, detailing any breaches.

A recent internal audit revealed that no breaches have been recorded in any of the registers for the last 12 months, even though your department dealt with a number of breaches that occurred during that period. What changes to the current system will you propose, what information do you propose be supplied to the head of compliance and how often do you recommend that reports be made in the future?

Question 2.

A recent increase in the volume of business being received has caused a backlog in completing the onboarding process. The delays are continuing to increase and are now causing these potential clients to complain, and this is stretching the resources of the onboarding team even further. The head of the onboarding team has asked to be allowed to onboard all customers immediately upon application, and then obtain the necessary documentation later when new staff can be recruited.

Identify the risks associated with the request and support your position with the key regulatory requirements and examples of the consequences of failing to meet these requirements.

Question 3.

Your firm has been suffering a decline in profits due to a downturn in the volume of sales. To increase revenue, the sales director has proposed that the firm launch a new, complex and high-risk product. Historically, your firm has not provided any complex products and the board are concerned about this strategy. The board members do, however, recognise that some action needs to be taken.

To address their concerns, you have been asked to provide a note that:

a) identifies the compliance risks related to the launch of high-risk and/or complex products

b) states how you would seek to mitigate the risks you identified in a) above

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