Annual Control Reviews of Conduct-related Activities: A Regulatory Imperative
Design and execution of a robust Annual Controls Review programme for a Universal Bank in Hong Kong, mandated by a US Regulator.
Client Need
The client required a partner to aid in developing and implementing a rigorous and effective Annual Controls Review programme as mandated by a US Regulator. The controls review programme was expected to address conduct-related controls activities across the bank's global operations, with a significant focus on their Global Banking and Markets division. The resultant data had to be accurately compiled into a comprehensive report, ready for submission to the US regulator. The requirements included:
1) The creation of a comprehensive internal controls testing environment and framework for both initial and continuous assessment of design and operational effectiveness.
2) A thorough review of the controls environment across key business operations, trading activities, and specified geographies (primarily Hong Kong and Singapore for the Asia Pacific segment of the project).
Role
We took the lead in the design and execution of controls testing, subsequently preparing the Asia Pacific section of the report to be submitted to the US regulator. We ensured full engagement with regional client operations and functions at both operational and senior management levels. This was crucial to guarantee that the assessment results of the controls environment were comprehensively and accurately represented in the final report delivered to the US regulator.
Value Added
Our robust review process and strategic approach facilitated an effective Annual Controls Review programme that adhered to the requirements of the US regulator, empowering the client to demonstrate compliance and maintain operational excellence.
1) We designed and implemented a comprehensive internal controls testing environment and framework. This included mechanisms for both initial and ongoing assessment of design and operating effectiveness, allowing for continuous improvements in control measures.
2) We executed a meticulous review of the controls environment, focusing on key business operations, trading activities, and geographies. The review specifically targeted the client's operations in Hong Kong and Singapore, providing valuable insights for the Asia Pacific segment of the project.