Top risks and controls for Compliance
The Compliance register lists 38 key risks and 97 best-practice controls across 5 units: Compliance Policy and Governance, Fraud Prevention and Investigation, Internal Audit, Regulatory Compliance, Training and Awareness. Use it to identify risks, benchmark your existing controls or start a risk and control self-assessment (RCSA).
AI-era lens: compliance teams are both users of AI (transaction monitoring, screening, regulatory change tracking) and the function that must show regulators AI is used fairly and lawfully. The units below cover the core compliance risks; the compliance risk for AI guide covers the new expectations.
A bank's compliance department is in charge of making sure that the bank complies with all applicable laws, rules, and industry standards.
Conducting risk assessments to identify potential compliance risks and vulnerabilities inside the operations of the bank is one of the primary tasks of the compliance department.
Risk assessments assist the compliance function in understanding how the bank operates, determining the degree of risk present in each area, and setting priorities for risk mitigation.
The compliance function can assist the bank in proactively managing compliance risks, averting potential regulatory violations, and defending the bank's good name and financial stability by conducting risk assessments.
Units covered
Compliance Policy and Governance: key risks and controls
Accountable for creating and maintaining the compliance policies, practices, and guidelines for the bank. They make ensuring that the compliance programme for the bank complies with all relevant laws, rules, and standards as well as industry best practices.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Balancing risk and compliance | Compliance policies are designed to mitigate risk, but sometimes strict adherence to policies can create additional risk. The compliance policy and governance team must balance the need for compliance with the need to manage risk effectively. |
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| Communication and training | Compliance policies and regulations can be complex and difficult to understand. The compliance policy and governance team must communicate policy changes and updates clearly to all relevant stakeholders within the bank, and provide appropriate training and guidance on how to comply with these policies. |
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| Keeping up with changing regulations | Compliance policies and regulations are constantly evolving, and it can be challenging to stay up-to-date with the latest changes. The compliance policy and governance team must continually monitor and interpret new regulations and guidance to ensure that the bank is in compliance. |
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| Managing data | Compliance policies often require the collection, analysis, and reporting of large amounts of data. The compliance policy and governance team must ensure that data is accurate, secure, and easily accessible to relevant stakeholders within the bank. |
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| Managing third-party relationships | Banks often work with a variety of third-party vendors and partners, each of whom may have their own compliance requirements. The compliance policy and governance team must ensure that third-party relationships are properly managed and compliant with relevant regulations. |
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| Technology implementation | Compliance policies often require the implementation of technology solutions to manage data and ensure compliance. The compliance policy and governance team must work with IT and other stakeholders to implement these solutions effectively and efficiently. |
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Fraud Prevention and Investigation: key risks and controls
Accountable for stopping and looking into fraud, both internal and external, committed against the bank or its clients.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Balancing fraud prevention with customer experience | While preventing fraud is a top priority, the fraud prevention and investigation team must also ensure that customer experience is not negatively impacted. Excessive security measures may inconvenience customers and lead to lost business. |
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| Collaboration with law enforcement | In cases of serious fraud, the fraud prevention and investigation team must work closely with law enforcement agencies. This can be challenging, as different agencies may have different priorities and approaches to investigations. |
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| Dealing with false positives | Fraud detection systems may flag legitimate transactions as potential fraud, leading to delays or inconveniences for customers. The fraud prevention and investigation team must have processes in place to quickly identify false positives and prevent unnecessary customer disruption. |
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| Gathering evidence | To investigate fraudulent activity, the fraud prevention and investigation team must gather evidence and build a case. This can be challenging, particularly if the fraudsters are operating across multiple jurisdictions or using sophisticated methods to cover their tracks. |
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| Keeping up with emerging fraud schemes | Fraudsters are constantly developing new and sophisticated schemes to defraud banks and their customers. The fraud prevention and investigation team must stay up-to-date with emerging threats and adapt their strategies accordingly. |
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| Maintaining confidentiality | Fraud investigations often involve sensitive information, and the fraud prevention and investigation team must ensure that confidentiality is maintained throughout the investigation process. |
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| Managing data | Fraud prevention and investigation require the collection and analysis of large amounts of data. The fraud prevention and investigation team must ensure that data is accurate, secure, and easily accessible to relevant stakeholders within the bank. |
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Internal Audit: key risks and controls
To make sure internal controls are effective and compliance risks are recognised and managed, this department is in charge of performing independent audits of the bank's activities, including its compliance programme.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Addressing cultural and behavioral challenges | Compliance is not just about following rules; it also involves fostering a culture of ethical behavior and ensuring that employees are aware of their compliance responsibilities. The regulatory compliance team must address cultural and behavioral challenges to ensure that compliance requirements are embedded into the bank's operations and culture. |
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| Addressing emerging risks | The internal audit team must identify and address emerging risks to the bank, such as cybersecurity and climate change, which may require new approaches and specialized skills. |
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| Attracting and retaining talent | The internal audit team must attract and retain skilled professionals with the expertise required to audit complex risk areas, such as cybersecurity and financial crime. |
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| Balancing compliance with business objectives | The regulatory compliance team must balance the need for compliance with the bank's business objectives. This can be challenging when compliance requirements may conflict with business strategies or goals. |
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| Balancing independence and collaboration | The internal audit team must maintain independence while collaborating with other departments within the bank. It can be challenging to strike the right balance between independence and collaboration, particularly when auditing departments where there may be resistance to audit findings. |
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| Data Accuracy | Auditing often involves the collection and analysis of large amounts of data. The internal audit team must ensure that data is accurate, secure, and easily accessible to relevant stakeholders within the bank. |
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| Ensuring consistency across the organization | The regulatory compliance team must ensure that compliance requirements are consistently applied across the organization, particularly in cases where the bank operates in multiple jurisdictions with different regulations and requirements. |
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| Ensuring coverage of all risk areas | The bank may have a wide range of risk areas, and it can be challenging for the internal audit team to ensure adequate coverage of all areas within a limited amount of time and resources. |
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| Keeping up with changing regulations | Internal audit teams must stay up-to-date with evolving regulations and compliance requirements to ensure that audit plans remain relevant and effective. |
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| Maintaining stakeholder trust | The internal audit team must maintain the trust and confidence of stakeholders, including senior management and the board. This can be challenging when audit findings may reveal weaknesses or gaps in the bank's operations or compliance practices. |
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| Managing data | Compliance often involves the collection and analysis of large amounts of data. The regulatory compliance team must ensure that data is accurate, secure, and easily accessible to relevant stakeholders within the bank and to regulators. |
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| Managing regulatory relationships | The regulatory compliance team must maintain positive relationships with regulators and ensure that the bank is responsive to regulatory inquiries and requests. |
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| Providing training and education | The regulatory compliance team must provide training and education to employees to ensure that they understand their compliance responsibilities and are equipped to comply with applicable laws, regulations, and industry standards. |
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Regulatory Compliance: key risks and controls
Accountable for ensuring that the bank abides by all relevant laws and rules, including those concerning consumer protection, know-your-customer (KYC), and anti-money laundering (AML).
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Balancing compliance with business needs | The compliance unit must balance the need for regulatory compliance with the bank's business objectives. This can be challenging, as compliance requirements may sometimes conflict with the bank's desire to grow and expand. |
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| Dealing with regulatory authorities | The compliance unit must interact with regulatory authorities, such as the Federal Reserve or the SEC, and ensure that the bank is meeting all regulatory requirements. This can involve responding to inquiries, providing documentation, and participating in audits and inspections. |
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| Ensuring employee compliance | The compliance unit must ensure that all bank employees are aware of and adhere to regulatory requirements. This may involve providing training, conducting audits, and establishing reporting mechanisms for potential compliance violations. |
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| Keeping up with regulatory changes | The regulatory environment is constantly evolving, and the regulatory compliance team must stay up-to-date with changes to regulations, laws, and industry standards to ensure that the bank remains compliant. |
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| Managing compliance risks | The compliance unit must identify and manage potential compliance risks, such as money laundering, fraud, and data breaches. This involves establishing policies and procedures, monitoring transactions, and investigating suspicious activity. |
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Training and Awareness: key risks and controls
Accountable for educating bank staff about compliance issues and giving them compliance training.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Addressing cultural and behavioral challenges | Compliance is not just about following rules; it also involves fostering a culture of ethical behavior and ensuring that employees are aware of their compliance responsibilities. The training and awareness team must address cultural and behavioral challenges to ensure that compliance requirements are embedded into the bank's operations and culture. |
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| Customizing training to different audiences | The training and awareness team must develop training programs that are tailored to different audiences within the bank, such as front-line employees, managers, and executives. This can be challenging when different audiences have different levels of knowledge and experience. |
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| Ensuring training is accessible and available | The training and awareness team must ensure that training programs are accessible to all employees and available in multiple formats, such as online, in-person, or on-demand. |
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| Ensuring training is engaging and effective | The training and awareness team must develop training programs that are engaging and effective in conveying complex compliance concepts to employees. This can be challenging when compliance topics may be dry or technical in nature. |
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| Keeping up with regulatory changes | The regulatory environment is constantly evolving, and the training and awareness team must stay up-to-date with changes to regulations, laws, and industry standards to ensure that the bank's training programs remain relevant and effective. |
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| Managing resources | The training and awareness team must manage resources effectively to ensure that training programs are delivered on time and within budget. |
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| Measuring the effectiveness of training | The training and awareness team must measure the effectiveness of training programs to ensure that they are achieving their intended goals and to identify areas for improvement. |
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This register is a starting point for risk identification and benchmarking against international practice. Adapt the risks and controls to your institution's size, products, jurisdiction and regulatory requirements.
Get the Compliance register as an RCSA workbook
A spreadsheet-ready CSV with every risk and control on this page, plus blank columns for control owner, inherent likelihood and impact, control design, operating effectiveness, residual rating and actions. We confirm your email with a 6-digit code, then email you the download link.
Frequently asked questions
What are the key risks in Compliance?
The main risk areas covered are Compliance Policy and Governance, Fraud Prevention and Investigation, Internal Audit, Regulatory Compliance, Training and Awareness. Each unit lists its key risks with a short explanation and the best-practice controls that mitigate them.
How do I use this register for a risk and control self-assessment?
Select the risks that apply to your units, map the listed controls to the controls you actually operate, rate inherent risk and control effectiveness, then agree actions for gaps. The free RCSA workbook on this page has the columns ready.
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