Chapter 9Compliance Outside the Compliance Department

Who needs to know about Compliance and regulatory requirements within your firm? The Compliance department? Your Investment Managers? The Legal department? Operations? Human Resources? The receptionist? The simple answer is that everyone working for a regulated firm needs to know about Compliance. ‘Compliance is everybody's business’ is a saying that has been adopted by senior management in a number of financial institutions around the world. It is designed to ensure that everybody understands the importance of Compliance and that the firm can demonstrate the need for a robust and healthy Compliance culture. The level of knowledge required will clearly vary greatly depending on a person's role and position within the firm but it is hard to think of anyone who does not need even the slightest awareness of how Compliance requirements can have a bearing on their role. Even a driver or messenger or temporary secretary needs to know not to act on price-sensitive information, for example, or not to leave documents lying around in case client details get into the wrong hands. At the other end of the scale, the heads of front and back office functions arguably need to be as familiar as you are with Compliance requirements in their specific area. It is your job to get them there. In order to do so you need to understand what they do – first, to establish which rules have an impact on them and, second, to meet them on their own ground, ...

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