Operationalising the rules.
WHAT IT REQUIRES
A designated responsible person Written policies Procedures staff actually follow Training Monitoring that controls operate Records demonstrating all of it
WHY RECORDS MATTER MOST
Compliance is demonstrated by evidence, not by intent.
WHAT TO DOCUMENT
The risk assessment The controls addressing each risk Who performs each control Evidence that it was performed
WHAT AUTOMATION SHOULD HANDLE
Screening Monitoring rules Record retention Report generation
WHAT MUST REMAIN HUMAN
Judgement on escalations Decisions to report Risk assessment
WHAT TO AVOID
Policies nobody reads Controls that exist on paper only Alerts nobody reviews
WHY THAT LAST POINT
An unreviewed alert queue is worse than no monitoring, since it demonstrates awareness without action.
WHAT TO REVIEW PERIODICALLY
Whether controls still address current risks Whether rules produce actionable alerts Whether staff understand their obligations
WHAT TO BUDGET
Compliance as continuing cost, scaling with growth.
WHAT TO ENGAGE
Legal counsel familiar with financial regulation, early.
