I recently had the pleasure of speaking at a conference in the City to an audience of senior representatives from wealth management firms, asset management firms and private banks. I opened my talk with a show of hands to two questions; the first question was “how many of the firms represented here today were subject to Accountability I ”. No hands were raised. My second question was “how many firms represented here today will be subject to Accountability II ” – Only 6 out of 120 delegates raised a hand.
The reality is that all the firms represented at that conference will, in some way, be affected by Accountability II. The regime will impact every senior manager and almost all staff within these firms.
Having conducted similar snap ‘barometer’ tests at other events and conferences, the lack of hands was not a surprise. It reflects my growing concern that while there is broad awareness and understanding of the regime amongst compliance professionals, there is a lack of awareness and/or engagement amongst the broader senior management community; the very group of people the regime is most targeted towards.
One of the comments after the conference was ‘Carl’s talk on Accountability II managed to scare the audience a lot more than the preceding talk on cyber security ’. That clearly wasn’t my intention, however, the change for some firms may be of avalanche proportions; affecting people, process and systems across the entire firm and wider group, if applicable. Accountability II cannot simply be implemented by ‘compliance’ teams in isolation. It requires all senior managers, execs and boards to be involved.
To help raise awareness amongst firms and senior managers, a copy of my presentation can be found by clicking here. The presentation covers the following points:
Carl Redfern, Compliance Director – Redland
By Redland from Redland Business Solutions
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