Compliance officer appointment, training and ongoing support

The appointment that is made late and badly

The pattern repeats itself: the finance manager is named in a minute, with no documented profile, no written duties, no time allocated and no direct access to the board. The company ends up with the post filled and with a weakness that shows in the first review it faces, because the compliance officer is not a signature on a minute but a function that has to be capable of being exercised.

Profile, duties and independence

• Profile. Knowledge of the business and of the regime, authority to decide, and no conflict with the areas the officer will be controlling.
• Written duties. What the officer does, signs, authorises and is obliged to escalate.
• Independence. Not reporting to whoever sells or whoever buys, and no remuneration tied to commercial results.
• Direct reporting. Access to the highest corporate body, at a defined frequency and with the ability to place reports on record.
• Resources. Time, information and tools. An officer with no access to the company's systems cannot monitor anything.

What the appointee takes on

This is better said before the appointment than after: the compliance officer takes on duties of their own and their performance is assessed. Before anyone signs the acceptance we explain what the role requires, what backing they should demand from management, and what record they should leave when a decision is taken against their advice. An appointment accepted without that conversation ends up being a problem for the individual and for the company.

Appointment and registration

We document the appointment with the minute of the competent body, the appointee's acceptance and the supporting profile, and we handle the registration filing before the Superintendence of Companies. We also provide for what is almost never provided for: what happens when the officer resigns, is off sick or changes roles, with a deputising rule and a replacement procedure, so the function does not fall vacant without anyone noticing. Where the appointment is being corrected rather than made for the first time, we also review what was filed before, so the record shows a coherent history and not two versions of the same fact.

Training the appointee

The person appointed is usually left alone facing a regime they do not know. We train them on what they will actually have to do: how an alert is analysed, how a decision not to report is documented, what is retained and for how long, how an information request is handled and what is reported to the board. We hand over the calendar of their obligations and the formats for their periodic reports, so they do not have to invent the structure each time.

Ongoing external support

Many covered companies have nobody to appoint: there is no individual with the profile, the time and the independence the role demands. For those cases we provide ongoing external support to the appointed officer, who remains responsible but stops being alone.

• A standing line for day-to-day cases, with a written answer where the decision is worth documenting.
• Review of complex alerts and of the analysis preceding a reporting decision.
• Preparation of the periodic reports to management and to the highest corporate body.
• Notice of the regulatory changes that require adjusting the programme.
• Updating the risk matrix and the manual when the operation changes.

What the client receives

• The job profile and the compliance officer's schedule of duties.
• The appointment minute, the acceptance and the supporting registration filing.
• The appointee's training, with materials and records.
• The calendar of obligations and the periodic report formats.
• Where ongoing support is engaged, a standing point of contact and the records of the support provided.