Leveraging human and financial resources to meet higher compliance expectations

The ongoing digitalisation and data-driven approaches in financial services require compliance functions to meet higher expectations. The compliance teams have increasingly obtained a role as trust enablers for the corporate brand and guardians of company reputation. To deliver value in the digital age, compliance must focus on outcomes at the company level instead of delivering outputs. This will require compliance to optimise and refine the interaction of human and financial resources at a higher level. To be in a position to meet these higher outcome expectations, compliance functions are required to enable holistic oversight across all entities and jurisdictions. This will require viewing compliance programmes as a system consisting of people, processes and tools. The recent Citibank case from October 2020 related to deficiencies in enterprise-wide and compliance risk management, as well as its data governance and internal controls, is leveraged to frame the selected approach. This paper defines three core levers which are required to be in place in order to introduce holistic compliance oversight based on system thinking: a new collaborative compliance programme governance, a single source of truth technology and a rigorous prioritisation of compliance talent agenda.