THOUGHT LEADERSHIP 1 THE 7 MIN COFFEE BREAK

THOUGHT LEADERSHIP 1 – THE 7 MIN COFFEE BREAK BEING A COMPLIANCE OFFICER OR MLRO IN A TIME OF CRISIS JAMES SHIMMIN

SCAMMERS AND THIEVES (INCL INTERNAL) WILL HIT YOU WHEN YOU ARE AT YOUR WEAKEST REGULATORS STILL EXPECT YOU TO BE COMPLIANT AT ALL TIMES …. DOCUMENT ALL DECISIONS AS IT WILL BE AUDITED IN THE FUTURE DO THE RIGHT THINGS AT THE RIGHT TIME FOR THE RIGHT REASON AND PROTECT YOUR LIVELIHOOD! IT GOES WITHOUT SAYING ……

LIST ALL THE TASKS BOTH OPERATIONAL AND REGULATORY AND THEIR FREQUENCY IDENTIFY TASKS WHICH ARE TIME SENSITIVE - ALLOCATE APPROPRIATE TIME TO ACHIEVE IF LOWER RISK THEN CAN REQUIREMENT BE RESCHEDULED – DETERMINE IMPACTS RISK BASED WORK SCHEDULE ENHANCES EFFICIENCY DETERMINING THE RISK – SIMPLE SUGGESTION S

DAILY MEETINGS WITH TEAM AND OTHER KEY PERSONNEL WEEKLY MEETINGS WITH BOARD (VIDEOLINK) ENSURE STAFF CAN EASILY ACCESS MLRO/CO INCL CONFIDENTIAL VIDEOLINK – EMAIL ENSURE ALL COMMUNICATION ARE DOCUMENTED AND AGREED – IF VIDEOLINK CONSIDER RECORDING IF CONTACT THE REGULATOR - DOCUMENT THE CALL - ENSURE THE OUTCOMES CONFIRMED IN WRITING MANAGEMENT TIP 1– COMMUNICATION

TREAT ALL INTERNAL DISCLOSURES AS PRIORITY YOUR INITIAL INVESTIGATION MAY BE RESTRICTED – MAKE SURE THIS IS DOCUMENTED IN SUBMISSION REMEMBER CONSENT RULES AND SECTION 24 REPORTS – LET LAW ENFORCEMENT WORK WITH YOU CONTINUE TO ACCUMULATE EVIDENCE AND PROGRAMME FULL SUBMISSION IN LINE WITH REQUIREMENTS. MANAGEMENT TIP 2 – UNUSUAL ACTIVITY (CLIENT)

DETERMINE RISK OF STAFF USING THEIR OWN MACHINES AND VIRUS/DATA LOSS SECURE LINK / 2 FA – WEEKLY AUDIT LOOK FOR LARGE DOWNLOADS TO HOME PC – IF SO WHY? LOOK FOR UNUSUAL “LOGIN” HOURS – FRAUD ATTEMPTED WHEN THEY THINK NO ONE ELSE IS LOOKING MANAGEMENT TIP 3 – UNUSUAL ACTIVITY (STAFF)

IDENTIFY WHAT NEEDS TO BE DONE AND PRIORITISE BASED ON RISK ALLOCATE TASKS AND RESPONSIBILITIES WITHIN TEAM TO ENSURE EFFICIENCY SUMMARY DIRECTORS/ STAKEHOLDERS KEPT AWARE OF KEY RISKS THROUGH EFFECTIVE COMMUNICATION. IF YOU ARE OVERWHELMED SEEK OUT A THIRD PARTY TO ASSIST

LOOKING AT DATA MANAGEMENT DATA SECURITY TIPS MANAGING BREACHES DURING LOCKDOWN THOUGHT MANAGEMEN T 2 – COMING SOON

JAMES SHIMMIN • • •