Compliance Procedures & Documentation

All regulated firms must have documented compliance procedures including a compliance manual. Firms should also ensure that the procedures are appropriate and fit the nature of the firm’s business.

There is no benefit in having compliance procedures that are hundreds of pages long. It is unlikely that staff will read them and keeping them up to date becomes a major challenge and resourcing issue.

Key documentation

The key document is the firm’s compliance manual. This should clearly state how the firm complies with its regulatory obligations – and which rules are within or outwith scope for compliance. The manual should reflect the firm’s activities and operations in practical ways. It should be clear and concise for all staff to read – and all staff should have access to the most up to date version. Version control is important also. The manual should be updated when necessary and reviewed formally at least annually.

Monitoring plan

The firm should also have an up to date risk based compliance monitoring plan. Further information on monitoring can be found

Gem Compliance Consulting has extensive experience of putting together new compliance procedures and reviewing existing compliance procedures. Our aim is to ensure that these reflect the firm’s activities and regulatory obligations but are also practical and straightforward enough for all staff to access and use.
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