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Qn 4 : What is understood by ‘a quality compliance monitoring programme’…
Qn 4 : What is understood by ‘a quality compliance monitoring programme’ and how such a programme can be executed under the direction and supervision of a senior compliance officer with emphasis on identifying exceptions and breaches and escalating them to designated personnel; and
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exceptions and breaches
In many instances, the compliance manual or the monitoring
manual, where one exists, will set out the course of action to be followed where
a non-routine and complex issue has arisen
Where the manual is silent or it is
not clear whether the matter is one that falls within the scope of the guidelines, a decision will have to be made as to the course of action to be followed. Much depends on the circumstances of each case
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This programme must be risk-based,
recognising that certain business areas in a firm and specific regulatory issues will
carry different levels of regulatory risk
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Informing the regulator
As a general rule, it is advisable to try to think about what remedial action to
take before telling a regulator about a regulatory breach
Regulators like to be proactively informed of problems, but they also like to be proactively informed of proposed solutions. They may not agree with the way in which a business proposes to solve a particular problem, but presenting a problem with a solution provides comfort to the regulator. The key to limiting the damage caused by a regulatory breach is as much about the way in which an organisation reacts to the breach as the breach itself.
? Quote from Yes Minister, Moral Dilemma