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Leveraging human and financial resources to meet higher compliance expectations
Journal of Financial Compliance,
4
(4),
353-362
(2021)
Abstract
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.
Keywords: compliance outcome; compliance budget; trust; reputation; digitalisation; data-driven; Citibank case; holistic compliance oversight; compliance programme; collaborative governance; single source of truth; governance risk compliance (GRC); compliance talent
The full article is available to subscribers to the journal.
Author's Biography
Dr Ilona Niemi is the Group Chief Compliance Officer for The Co-operators Group Limited in Canada. Ilona oversees the enterprise compliance programme for property and casualty insurance, life insurance, mutual funds and investment management operations. Until May 2020, Ilona was VP, Head of Compliance for Zurich Canada and part of Zurich Canada Executive Leadership Team. Prior to transferring to Zurich Canada, Ilona held the role of Head of Global Compliance Oversight and Reporting at Zurich Insurance Company in Switzerland, having responsibility for driving compliance insights across 60 business units and five regions. Ilona joined Zurich Insurance Company in 2008 as Head of Corporate Center Public Policy Issues. Preceding that, Ilona had varying positions in management, strategy and communications consulting in Germany and Washington D.C. and served as EU policy adviser in Brussels. Ilona is the author of the book ’EU Council Presidency in an Enlarged European Union’ and is a frequent speaker at regulatory and compliance conferences. Ilona serves as an advisory council member for the Ted Rogers School of Management’s law and business programme at Ryerson University in Toronto. She is an advisory board member for Osgoode Hall Law School’s regulatory compliance management programme at York University in Toronto and part of the programme’s faculty since 2018.
