The devastating events of September 11, 2001, created a unified resolve to fight terrorism in this country. One industry required to bear a substantial burden is that of financial institutions. New requirements from the USA PATRIOT Act and the Office of Foreign Assets Control include verifying the identity of every new customer and checking customer databases against government watch lists to find potential terrorist threats. Compliance management is a source of concern for many financial institutions.

Implementing Compliance Management

The first step is adopting a committed attitude. The security of the country depends on financial institutions that care enough to pay attention to details. Company culture starts at the top and filters down to every employee. An emphasis on integrity and patriotism will pay dividends. An attitude of annoyance could create failure.

It is helpful to set controls to achieve successful compliance management. Policy controls would include written statements and procedures. Operational controls would be data collecting, monitoring, storing, analyzing, and responding. Technical controls involve automated, software, and web-based programs to provide efficiency and cost-effective results while maintaining security and privacy.

Noncompliance could result in penalties such as ratings downgrades and fines. Institutions should begin now to anticipate upcoming deadlines. It takes time to establish a workable program. Place someone in charge who is capable of managing complex requirements. It is helpful to remember that compliance management is a process that must change and adapt as new mandates are issued.