The Conditions Are Right For TakingDecisive Action To ImproveEffectiveness AndEfficiency A playbook for complianceleaders Allen MeyerVivian Merker NOW IS THE RIGHT TIME TO TACKLE COMPLIANCETRANSFORMATION Financial institutions (FIs) have historically struggled to reduce compliance spending dueto regulatory pressures that raise expectations for compliance programs. With financialinstitution leadership potentially anticipating lower regulatory burdens and heightenedprofit margin expectations, there is a risk of substancial budget cuts across the enterprisethat may compromise compliance programs. In our recent interactions with chief complianceofficers (CCOs), we’ve seen evidence that the pressure to cut costs while maintaining orimproving effectiveness is intensifying, including thefollowing: •Anticipated lowering of regulatory pressure and more support for innovation underthe Trump administration•Massive new capabilities unleashed by advancements in Artificial Intelligence(AI) technology•Sustained cost pressures from volatility and strain in the business environment Fortunately, transforming compliance processes presents a significant opportunity forfinancial institutions, as approximately 60% of compliance team activity is executingprocesses that are ripe for transformation, (for example, law, rule and regulation (LRR)mapping to risk taxonomies, policies, procedures and controls; investigations; monitoringand testing), based on Oliver Wymanbenchmarking and calculations. By implementingintelligent transformation strategies, compliance leaders can proactively navigate thischallenge. Leading-edge Oliver Wyman clients have achieved remarkable success, reducingoverall compliance costs by 15% to 30% while enhancing efficiency across their programwithout compromisingeffectiveness. In this paper, we introduce Oliver Wyman’s Process-Driven Approach to ComplianceTransformation, a strategic framework that advocates for a process-forward methodology,focusing on the simplification of existing procedures and the enhancement of theirinterconnections. We will explore how this approach not only addresses currentinefficiencies in a holistic, risk-sensitive, and sequential manner but also preparesorganizations for future challenges. CHALLENGES WITH CURRENT STRATEGIES According toOliver Wyman and the Risk Management Association’s Annual ChiefCompliance Officer Survey from 2024 (CCO Survey), 70% of compliance teams report growingheadcounts over the last two years, but many anticipate budget constraints and a new eraof doing more with less. In addition, we are seeing a pronounced shift in priorities fromregulatory remediation to effectiveness and efficiency. This presents a critical opportunityfor transformation. However, classic top-down firmwide cost-reduction programs do not consider the nuancesof compliance programs and the very specific and bespoke expectations of regulators (forexample, the need for an FI to maintain a comprehensive LRRs). As a result, they oftenincrease compliance risk over time. A well-designed program can help insulate compliancefunction from generic approaches while maintaining the efficacy of compliance programsacross the regulatory cycles. PROCESS-DRIVEN APPROACH FOR COMPLIANCETRANSFORMATION In our experience, compliance programs often rely on risk management processes thatare manual narrative-based, and only loosely connected to each other processes. Theseare prime candidates for transformation. The question is how FIs should take actionto transform compliance to reduce costs while maintaining and improving efficacy.Oliver Wyman believes the answer is to take a process-forward approach to transformation,which encompasses two dimensions: Enhance thelinkages betweenprocesses Simplify andstreamlineexisting processes A mixture of standard process redesign and efficiency levers (such as offshoring or near-shoring exercises) and newer levers (like deployment of large language models with “humanin the loop” safeguards) can lead to very substantial effectiveness and efficiency uplifts ifthey are embedded in a holistic strategy and executed in a coordinated manner. We believethat this is the time to mobilize these efforts since the changing economic environment maylead to the imposition of unilateral and speedy cost-cutting requirements from FI seniormanagement (for example, outright headcountreductions). The key to developing a thoughtful strategy for reducing costs and improving effectivenessis to identify processes that require the most routine manual intervention by complianceteams and are taking valuable time away from analytical and complex risk reductionactivities. Processes that are ripe for transformation should be matched with the rightlevers to improve effectiveness and drive efficiency based on their requirements andcharacteristics. The resulting opportunities should be organized into an ambitious yetrealistic plan. Approach.Analyze opportunitieswith Oliver Wyman's library ofcomp