Our expertise
Business Compliance — Investment services compliance framework
Use Case
Investment services compliance framework
Following an investment services provider (ISP) accreditation and an audit by the AMF that identified non-compliance issues, head of compliance department decided to conduct an assessment of the investment services compliance framework in order to implement a remediation plan
Valthena assisted the client in conducting the diagnosis, developing the action plan, and providing operational oversight for the remediation
The scope of the study includes:
- Reception and transmission of orders for third parties, execution of orders for third parties, portfolio management for third parties, investment advice, account holding/custody
- Insurance broker status for life insurance
- MiFID and DDA regulations
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Approach
The project was structured around several phases:
Assessment / diagnosis of the compliance framework
- Exhaustive identification of non-compliance issues
- Assessment of non-compliance risk
- Evaluation of the degree of priority for actions based on operational and regulatory risk levels of non-compliance
Development of the remediation plan
- Definition of action plan / remediation plan in collaboration with business units
- Presentation and validation of the action plan with senior management
Remediation oversight
- Oversight of responses to commitments made to the AMF
- Oversight of the implementation of the action plan
- Participation in operational implementation work in collaboration with business units and compliance (operational processes, procedures, business requirements…)
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Results
- Comprehensive review of obligations under MiFID and DDA,
- Mapping of residual non-compliance risks,
- Remediation plan,
- Oversight of responses to the AMF