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Getting controls under control
Journal of Financial Compliance,
6
(3),
240-247
(2023)
Abstract
Organisational decision making related to compliance programmes often centres around the costs of compliance. Instead, compliance leaders within organisations should reframe the discussion around value. This paper discusses mechanisms to measure and capture the value of compliance through a tailored set of controls. It seeks to define compliance controls, discuss the consequences of ineffective controls, and describe examples of effective controls related to staffing, testing and technology, which can guide compliance leaders in updating their compliance programmes. Further, the paper proposes the development of a return-on-investment metric for compliance controls and considers how this may materialise in practice.
Keywords: controls; processes; ROI; swap dealers; reputation; effectiveness
The full article is available to subscribers to the journal.
Author's Biography
Jamila Piracci is Senior Advisor at Patomak Global Partners, a regulatory strategy and compliance consultancy. She serves on the boards of the Futures Industry Association and SwapEx, LLC, and is a member of the Advisory Board of Hidden Road Partners. Prior to joining Patomak, she led the National Futures Association's (NFA's) regulatory programme from 2011 to 2019, overseeing swap dealers under the Dodd–Frank Act, including creating NFA's programme. Her work at NFA included hiring and managing a staff of nearly 120 examination, internal audit, operations, risk and quantitative staff that monitored and approved margin models for swap dealers subject to Commodity Futures Trading Commission requirements. Ms Piracci previously worked at the Federal Reserve Bank of New York (NY Fed), where she was an attorney with a primary focus on orderly liquidation authority and resolution planning under the Dodd–Frank Act, as well as on market and other developments pertaining to OTC derivatives. Prior to joining the NY Fed, Ms Piracci spent nearly a decade advising a range of OTC derivatives market participants, including dealer banks, investment managers and energy firms. Ms Piracci also was an assistant general counsel at the International Swaps and Derivatives Association. She received her JD from Cornell Law School and MBA from the S.C. Johnson Graduate School of Management at Cornell University. Ms Piracci earned her AB from Harvard-Radcliffe College at Harvard University.
Christopher Beckmann is a senior analyst at Patomak Global Partners, where he focuses on projects involving digital assets and banking regulation. Prior to joining Patomak, Chris did federal and state government affairs work for Childhelp, a non-profit organisation serving child abuse victims. On Capitol Hill, Chris spent three years in both the House and Senate working for Martha McSally, where he served as a legislative aide managing the appropriations and transportation portfolios for the office. Chris received his BA from Johns Hopkins University.
