SAGRILAFT and PTEE audit and preparation for a supervisory visit

Reviewing an existing programme from the outside

Where a SAGRILAFT or a PTEE has already been adopted, the job is not to rewrite it: it is to establish how defensible it is. We review it against two references, and both matter. The first is the applicable circular. The second, which usually reveals more, is the company's real operation: if the manual says a document is requested and the files do not contain it, the gap is there and not in the drafting.

What we look at

• Coverage and regime. Whether the company is still under the regime it adopted the programme for, or has changed category without noticing.
• Risk matrix. Whether it matches the current operation, whether the controls exist and whether anyone actually runs them.
• Counterparty files. A sample review of recent onboardings, which is where the gaps show up.
• Minutes and reports. Approvals, compliance officer reports and evidence that the highest corporate body was informed and decided.
• Training. Coverage, content by role and attendance records.
• Alerts and decisions. Whether alerts were analysed, who decided and whether the decision was documented with its reasoning.
• Third parties. Due diligence on agents and intermediaries and compliance clauses in the contracts in force.

The gap report

We deliver a report stating what is missing, what is incomplete and what is sound, with a remediation plan prioritised by risk rather than by ease. We distinguish what has to be fixed before a visit, what can be tidied up during the quarter and what can wait for the next annual review. Each item carries a suggested owner and the evidence expected, so progress can be measured and does not depend on anyone's memory.

Preparing for a visit or an audit

When a visit has been announced, a due diligence is under way or an institutional customer is about to audit, the pace of the work changes.

• We organise the programme file so that what exists can be produced at the moment it is asked for.
• We prepare the people who will be interviewed on the scope of their own role, not on a script.
• We define who receives the officials, what is handed over and how each delivery is recorded.
• We review in advance the points where the programme is weak, so the company does not learn about them during the visit.

When the request has already arrived

A request from the Superintendence of Companies carries a deadline, and everything filed stays on the record. We check the date of service and the real scope of what is being asked, reconstruct the facts internally before replying, and prepare the response together with its supporting documents. If the matter moves towards an administrative investigation, we take on the technical defence of the company and flag from the outset when the directors and officers need a separate position, because in these proceedings the exposure is not the company's alone.

What the client receives

• The audit report with the gaps identified and the basis for each one.
• The prioritised remediation plan, with suggested owners and expected evidence.
• The corrected documents, where the agreed scope includes remediation.
• The protocol for handling visits and requests, with a short version that can be consulted on the spot.
• The responses filed with the authority and the follow-up of the proceeding.

Typical situations we handle

• The programme was adopted years ago and nobody has looked at it since.
• A buyer or an investor is reviewing compliance as part of a due diligence.
• The company changed in size, markets or channels and the programme now describes a business that no longer exists.
• A request has arrived or a visit has been announced, and the company needs to know where it stands before the authority does.