Enterprise Compliance Risk Management

Chapter 7Operationalizing Compliance

“A journey of a thousand miles begins with a single step.”

—Lao Tzu

“Well begun is half done.”

—Aristotle

Having defined the strategy and set in place the structural framework, the next step is to enable a comprehensive yet flexible operational construct. It is the operational construct that I have seen as most challenging both in designing as well as in implementation. This is so because, as they say, “The devil is always in details.” Meeting the twin demands of simple yet comprehensive (at the same time) on the one end and well defined yet flexible on the other is no mean task. This chapter attempts to create an operational framework, with indicative templates that can be fine-tuned/retailored for individual firms.

Operational Framework

Operationalizing requires creating a working model that smoothly captures both the design and execution aspects of the entire life cycle of data and information management (Figure 7.1). Broadly, the design set would include the structures referred to as “Registers” and the related workflows. They help to record data with the required detail. Given the ever increasing regulatory and market demand for disclosures, it makes great sense to capture data at a granular level. Fine-grained data would help aggregations at different levels. The execution is the day-to-day implementation and management of the various aspects of compliance.

Figure 7.1 Operational Framework

The framework for it to be successful ...