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Compliance Officer Reports Key Issues & Considerations BVI Association of Compliance Officers. Presented by Simone E. Martin, MBA, FICA Deputy Director, Fiduciary Services BVI Financial Services Commission. Overview. Components of the Compliance Officer Report A section by section review.

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Compliance officer reports key issues considerations bvi association of compliance officers

Compliance Officer Reports Key Issues & ConsiderationsBVI Association of Compliance Officers

Presented by Simone E. Martin, MBA, FICA

Deputy Director, Fiduciary Services

BVI Financial Services Commission


Overview
Overview

  • Components of the Compliance Officer Report

    • A section by section review.

    • Useful considerations and other points.

  • Concerns and Observations


Overview1
Overview

  • Beyond the Compliance Officer Report.

    • What else should Compliance Officers be minded of?

  • Conclusions


Components of the compliance officer report
Components of the Compliance Officer Report

  • A Compliance Officer Report should be submitted in the form and context of section 48 of the Code.

    Section 48 of the Code provides that,

    “The report submitted by the compliance officer shall at a minimum contain the following:


Components of the compliance officer report1
Components of the Compliance Officer Report

Section 48(1)(a)

  • the training register


Components of the compliance officer report2
Components of the Compliance Officer Report

Section 48(1)(b)

  • a list of any legislative breaches, along with the remedial action taken.


Components of the compliance officer report3
Components of the Compliance Officer Report

Section 48(1)(c)

  • total number of SARs filed


Components of the compliance officer report4
Components of the Compliance Officer Report

Section 48(1)(d)

  • a list of significant complaints made by customers


Components of the compliance officer report5
Components of the Compliance Officer Report

Section 48(1)(e)

  • significant breakdowns in the internal control structure


Concerns observations
Concerns / Observations

  • Breaches reported and no comments on what remedial action is to be taken.


Concerns observations1
Concerns / Observations

  • Directors contradicting the Compliance Officer Report.


Concerns observations2
Concerns / Observations

  • Incorrect information, discrepancies and misinformation.


Concerns observations3
Concerns / Observations

  • Subjective comments and conclusions that are not supported by other filings and/or findings.


Beyond the compliance officer report
Beyond the Compliance Officer Report

  • Other statutory obligations.

    • immediately reporting to the Commission any serious compliance breach

    • maintenance of a Register of Compliance breaches


Beyond the compliance officer report1
Beyond the Compliance Officer Report

  • Ensure the licensee meets its reporting obligations.


Beyond the compliance officer report2
Beyond the Compliance Officer Report

  • Identify, measure and assess the compliance risks associated with the licensee’s business.


Conclusions
Conclusions

  • Take away points for Compliance Officers:-

    • Ensure quality reports with relevant information


Conclusions1
Conclusions

  • Obligations of a Compliance Officer extend far beyond the Compliance Officer Report.


Conclusions2
Conclusions

Questions / Comments


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