Policy framework

Business Case
An international Dutch bank aims to ensure that its compliance policy framework is aligned with current regulatory requirements and industry best practices, by conducting a thorough review of the existing policies and procedures, identifying areas that need to be updated, and developing new policies and procedures as needed.
The bank recognizes that compliance policies must be regularly reviewed and updated in order to keep pace with changes in regulations, and to ensure that the bank is effectively managing compliance risks.
To address this need, the bank has decided to undertake an initiative to update its compliance policy framework.
We designed a comprehensive policy framework that addressed current regulatory requirements and industry best practices. This framework included the development of standards and procedures to ensure compliance and consistency in the implementation of these policies.
We implemented effective communication and awareness training for management and employees to ensure that the new policy framework was effectively communicated and understood by all stakeholders. The training was designed to provide a clear understanding of the new policies, standards, and procedures, and how to implement them effectively. We also made ourselves available to the organization to answer questions and provide advice as needed to ensure that they were always able to access expert guidance and support.
We assisted the bank in changing its perspective on tax evasion, the importance of customer due diligence, and compliance. One of the many interventions was the updating of CEB’s compliance policy framework (Conflict of Interest Policy, FATCA Policy, Services in Financial Instruments Policy, etc.) as well as the development and implementation of numerous internal trainings. This included tax integrity training that focused not only on FATCA and CRS, but also on other relevant developments in the area of tax evasion and tax avoidance.