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Procedures / Employees (OSPs often provide the following (Induction…
Procedures / Employees
In order to demonstrate that the OSP has robust risk management systems, OSPs should have written policies and procedures that prescribe the way that trusts and companies are administered
The procedures must be robust and assist the business to identify and manage risks including the regulatory risk
The procedures should cover key areas of the business such as the risk rating of the customers, the acceptance of new business and AML provisions
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For the procedures to be an effective risk management tool, employees must be aware of them and be required to follow them
At time policies and procedures can appear to delay or needlessly complicate the provision of services to the clients. The policies and procedures of an organisation usually exist to protect the organisation or its employees against a risk that more junior employees might not understand
The origination may be required to maintain some procedures (covering AML and countering the finance of terrorism)) by law. Other policies and procedures may exist in order to ensure that the TSP does not act outside of its licence to conduct financial services business
An administrator who seeks to understand the reason for the existence of such policies and procedures will enhance their technical knowledge and will be in a position to add value to their organisation by giving feedback to management on the effectiveness and efficiency of its policies and procedures
Given the level of regulation that OSPs are subject to it is important that their staff are skilled and competent persons
The demand for professionals to be members of such bodies in some offshore jurisdictions may in part be driven by codes of practice issued by the regulator which impose a requirement for TSPs to have minimum levels of qualified staff eg in Jersey 75% of the staff that are decision makers must have attained a relevant qualification at diploma level or higher
It is a requirement in many offshore jurisdictions that employees complete CPD. The requirement is intended to help ensure that employees remain competent for their role by remaining up to date in their area of expertise
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Senior managers and directors of regulated entities may depending on the offshore jurisdiction be expected but not obliged to hold relevant professional qualifications such as
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