2021年合规成本：塑造未来

By Susannah Hammond & Mike Cowan Contents Shaping the future EXECUTIVE SUMMARY Regulatory Intelligence has carried out its 12th annualsurvey on the cost of compliance, focusing on thechallenges the compliance functions at financial servicesfirms expect to face in the year ahead. The report reflects Compliance officers seem to be taking a pragmatic view.The trend in recent years has largely been to keep budgetlevels the same, with perhaps slight increases. This yearreinforces that trend. Out of more than 720 respondentsto the survey, 36% of respondents predicted budgets will The inflection point raised in last year’s report has turnedinto a need for compliance officers to plan for the futureand develop a vision that manages a firm’s compliance and Cultural A risk-aware culture is perhaps the most valuable assetthat a firm can develop, especially when confronted witha changing environment. Such a culture will enable it,and its employees, to weather uncertainty and changemore effectively. Boards of financial services firms have The COVID-19 pandemic has required people to makefundamental changes to the way they live. From socialdistancing to wearing masks, washing hands to lockdowns,everyone has been affected. Financial services staff have The top compliance challenge that boards and complianceofficers were expecting to face was the increasing volumeof change, particularly driven by a new administration inthe United States and the aftermath of Brexit. The amount The Cost of Compliance report was also affected. In 2020,there were two such reports – the customary annual reportand a second update to take account of the impact of thepandemic1. In keeping with the wider social environment,the message from both reports was the need for change. Half of survey respondents expect the personal liability ofcompliance professionals to increase in the next 12 months,10% of them expect it to increase significantly. In the lightof these findings, perhaps, 62% of respondents said they Last year’s report had already identified that firms werestarting to reprioritize their compliance needs in line withthe amended regulatory agenda. The pandemic then acted The survey asked what respondents saw as the singlebiggest challenge to managing culture and conduct risk.Balancing competitive pressures and managing a remoteteam came out as the top two. A third of respondents This mix of sometimes competing pressures has seen firmsadopt changes in strategic direction, culture, governanceoperations and staff management. The crisis has shown Given the increasing professional and personal risk to boardmembers it is understandable they see compliance cultureas a challenge for 2021. The pandemic will undoubtedlyhave changed the ways in which firms evidence culture,but if an effective compliance culture existed prior to the The 2021 report highlights a need to support these widercultural, operational (including technology) and peoplerequirements but all will require future investment andresources. Financial limitations present a barrier tosuccessful change, and in the aftermath of the pandemic months were budget cuts (47%) and remote working (47%).In terms of likely turnover, 68% expected the turnover ofsenior compliance to stay the same in the next 12 months Operational Technology has been at the heart of the firms’ ability tochange. The Regulatory Intelligence report “Fintech,Regtech and the Role of Compliance for 2021”2found16% of firms have implemented a regtech3solution, with afurther 34% reporting that regtech solutions were affectingthe management of compliance. Compliance functions are Respondents saw a lack of necessary skills as one of themain challenges they would face in 2021. As firms andcompliance functions develop, there will be a need fora broader range of skills. The top three skills requiredfor an ideal compliance officer in 2021 were subject The wider use of technology has also made some firmsmore likely to outsource compliance functions. This year’sCost of Compliance report said a third (34%) of firmsoutsource all or part of their compliance functionality. Inthe G-SIFI population, however, compliance functionality Shaping the future As well as problems, the pandemic also presented thefinancial services industry and compliance officers withopportunities. Compliance officers must now build on thechanges which the pandemic forced on them. They will The adoption of technology often influences the drive forchange. Regtech can help with the prevention of financialcrime, and with compliance monitoring and regulatory A review, design, prepare, implement and support approachmay prove a useful methodology for progressing changes.Compliance officers can review existing arrangements, fromresponsibilities to information flows, create a vision of how People Compliance officers could use the changes that took placeduring 2020 as an opportunity to develop more in-depthstrategies for the future. For example, they ca