Essential Strategies for Financial Services Compliance, 2nd Edition

Chapter 5Mapping Your Corporate Universe

This chapter provides guidance on the type of basic standing data that you should have on the operating entities, business units and external services providers that fall within your remit.

5.1 Operating Entities

First comes a very basic task: make a list of all the operating entities within your group for which you have responsibility. Then make a list of the operating entities for which you do not have responsibility. For some, this will be very straightforward, but for others, less so. For example, if you are the Compliance Officer for a single regulated firm located in the UK, which has no parent company, subsidiaries or other affiliates, this area of your universe will be less complex than for others working for multi-branch, international financial groups. Which of the following do you have responsibility for?

• UK branch offices.
• Overseas branch offices.
• UK representative offices of group firms overseas.
• Overseas representative offices of a UK entity.
• More than one UK-regulated firm within your own group.
• Non-regulated firms within your own group. (Watch out – these might not be regulated by the PRA or FCA, but perhaps they are governed by other requirements such as your corporate best practice standards and policies, data protection law, rules set by a lead regulator based overseas, etc. You also need to check that some clever clogs does not suddenly decide to book a trade through one of these unregulated entities that could result ...