What is Compliance anyway?

Ostensibly, the job is to implement and monitor procedures to meet regulatory requirements, as well as advise and assist those carrying them out - tasks which generate an endless array of challenges. Adam Samuel unpacks this responsible and multi-faceted role, with its sometimes "highly contradictory skills".

Adam SamuelBA LLM DipPFS MCISI FCIArb Certs CII (MP&ER) Barrister and Attorney may be contacted through www.adamsamuel.com. His 'Compliance: A Short Book' is due out in January/February 2024. For links to where you can buy this and the second edition of 'Consumer Financial Services Complaints and Compensation', seewww.adamsamuel.com/writing.

Financial services literature contains vast numbers of references to 'compliance' every year. Usually, they relate to specific requirements imposed by regulators in plethora of areas. At the time of writing, the PDF version of the Financial Conduct Authority's SUP rulebook weighs in at an imposing 1,436 pages. We have huge commentaries on how to comply with these piles of words. I am even guilty of some of it: thousands of published pages on the complaint and conduct of business rules. Do we ever think about it, what it involves, who should be doing it, how should they be tackling these crucial tasks and of what those activities actually consist? There are some textbook answers, some found in places like SYSC 6: draft the procedures, advise and monitor - but is that enough? If the Compliance Department does not understand its function or cannot communicate it to the rest of the business, is it a surprise that businesses complain bitterly and consistently about the uselessness of its interventions?