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Implementing Compliance Culture across the firm: Overcoming Challenges and Winning Votes Ian Lyall, Managing Director, Compliance J.P.Morgan, London Riyadh, March 24, 2010. Background. Amalagamation of many firms since the early 90’s Business and Regional Differences
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Implementing Compliance Culture across the firm:Overcoming Challenges and Winning Votes Ian Lyall, Managing Director, ComplianceJ.P.Morgan, LondonRiyadh, March 24, 2010
Background • Amalagamation of many firms since the early 90’s • Business and Regional Differences • How do we define Compliance Culture • What are the implications of the wrong sort of culture? • Some differences in culture • Changes in the current environment The views expressed are personal to the speaker and not necessarily those of J.P.Morgan.
Practical Steps • Tone must be set from the top in words and by example • Requirements must be clearly set out • Code of Conduct • Definition of acceptable and unacceptable practices • Training and Awareness • Clear Compliance policies • Escalation/Challenge must be encouraged
Practical Steps 2 • Compliance involvement in all key committees and processes. Right to say ‘no’ • Be imbedded in the business, sit with the business, know their plans • Be available and let staff know that you are • Explain your decisions • Set your own high standards
Conclusion • Consistency is a challenge • Compliance is owned by Management but we must be counselling, educating and advising constantly • Training must be comprehensive and policies clear • Compliance must be seen and available and involved in all aspects of the business