Are you complying with your AFSL? Simple steps to success
When you are busy applying for your license or launching new funds you are really conscious of having legal review everything, but after these are done, it is easy to put the company’s compliance plan on the back burner. This is until the compliance committee rolls around and the dread sinks in … are we compliant? what have we missed? what did we agree to get done this quarter?
So, how do you make it manageable?
Having a clear and concise compliance plan is the starting point. The compliance plan should be specific to your license and cover off the key areas including:
Reporting obligations - what and when?
Maintaining Organisational Competence - ensure your Responsible Managers are properly appointed (or removed) and up to date with annual training plans.
Representatives - appointing, training, supervising and monitoring.
Conflicts of Interest are managed and monitored.
Adequate resources to provide financial services - Human, Technological, Cyber and Financial.
Financial management including NTA cash holdings, cash flow projections and lending covenants.
Breaches are identified, recorded and managed.
Outsourced services - are being monitored.
AML/CTF Plan is in action.
Once you have your plan in place, its a matter of maintaining it.
The key things for keeping on top of your plan include having registers and a system to keep documents.
A compliance calendar is a must to remind you when things are due. An online compliance portal is a great way to keep track and provide quick and easy reporting.
Building compliance into the day to day as something that belongs to everyone and not a a separate issue will ease the compliance committee dread. Keep it simple but effective.
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