Styperson POPE

Strategy & Compliance for Investment Firms

Interim Compliance Officer

Losing a colleague at short notice is always difficult but if your firm is FSA authorised, and the person you lose is a Compliance Officer, it’s essential to find an Interim Compliance Officer as quickly as possible.  Quite apart from the day-to-day compliance issues, and the risk of running up considerable costs for external advice, the FSA demands that all firms have a Compliance Officer:

A firm which carries on designated investment business… must allocate to a director or senior manager the function of having responsibility for oversight of the firm’s compliance.

We recently carried out an ICAAP risk assessment for a client firm which revealed that losing their Compliance Officer would have a greater financial impact on the business than losing their Chief Executive!  Firms must also be careful to ensure that whoever looks after the role, even for a short period, is sufficiently knowledgeable and experienced to carry it out.

An approved person performing a significant influence function must exercise due skill, care and diligence in managing the business of the firm for which he is responsible in his controlled function.

We can provide an Interim Compliance Officer with the necessary skills to fulfil the FSA’s requirements but, much more importantly, with the experience of working at Board level and capable of quickly understanding your business while playing a full role in the strategic direction of compliance matters.  We can also take responsibility for training up your permanent replacement and will gladly stay on as a mentor or just to give occasional advice on more specialised subjects.

Simon Webber, who will act as Interim Compliance Officer, serves permanently on a number of Boards either as Head of Compliance, Director or Non-Executive Director.  If you would like to speak to Simon about any aspect of compliance, please call or e-mail him.

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