Introduction

At Assured Support, we believe that data-driven insights are the key to elevating compliance practices and fostering robust organisational cultures in the financial services industry. As part of our commitment to helping our clients “see more,” we recently conducted a comprehensive cultural diagnostic and compliance assessment survey. This initiative reflects our ongoing dedication to providing cutting-edge, evidence-based solutions beyond conventional compliance consulting.

Our survey, designed to probe the intricate landscape of compliance and cultural practices across various financial services firms, focused on eight critical indicators:

1. Code of Conduct
2. Tailored Training
3. Business Improvement
4. Monitoring and Supervision
5. Resourcing
6. Capability and Competence
7. Regulatory Change Management
8. Openness to Challenge

By leveraging our extensive industry experience and our unique position in the market, we’ve gathered valuable data that offers unprecedented insights into the current state of compliance and organisational culture in the financial services sector. This article presents an in-depth analysis of the responses from participants representing a diverse range of licensees and business maturities.

Our findings highlight areas of strength and concern and provide a foundation for benchmarking and continuous improvement. Through this analysis, we aim to equip firms with the knowledge they need to enhance their practices while also offering regulators a clearer picture of where to focus their efforts.

At Assured Support, we pride ourselves on our ability to “see more” – to uncover patterns, identify emerging trends, and provide strategic insights that others might miss. This survey and its analysis exemplify our data-centric approach, offering a unique window into the compliance landscape that can drive meaningful change and improvement across the industry.

As you delve into the following sections, you’ll gain access to exclusive insights that can help shape your approach to compliance and organisational culture. Let’s explore together what it means to truly “see more” in financial services compliance.

Respondent Profiles

The survey respondents represent a cross-section of the financial services industry:

• 44.4% Self-Licensed Businesses

• 22.2% Corporate Authorised Representatives

• 22.2% Institutional Licensees

• 11.1% Not Authorized

In terms of business maturity:

• 11.1% ‘Start-up’

• 66.7% ‘Established and growing’

• 22.2% ‘Mature or sophisticated’

This diversity of respondents allows us to compare practices across different types of firms and stages of business development.

Key Findings

1. Code of Conduct

A code of conduct is fundamental to an organisation’s ethical framework. The survey revealed:

• 44.4% of respondents have a properly enforced Code of Conduct

• 33.3% have a Code, but it’s not enforced or rarely enforced

• 22.2% have no Code of Conduct

This indicates that while most firms have a code of conduct, there are significant gaps in enforcement and implementation. The lack of a code of conduct at some firms is concerning, as it may indicate a weak foundation for ethical decision-making.

2. Tailored Training

Regular, tailored training ensures employees understand compliance requirements and can apply them in their daily work. The survey found:

• 44.4% of respondents provide training, but only half of these with customised content

• 55.6% of respondents do not provide training or haven’t in the last 12 months

The lack of training at over half of the surveyed firms is a major red flag. Even among those providing training, only half offer customised content tailored to their business needs and risks.

3. Business Improvement

Continuous improvement is essential for adapting to regulatory requirements and industry best practices. The responses showed:

• 55.6% of respondents view business improvement as an ongoing process

• 44.4% of respondents do not have a business improvement process or rarely assess it

While it’s encouraging that over half of respondents focus on continuous improvement, a significant portion need more formal processes for enhancing their practices over time.

4. Monitoring and Supervision

Effective monitoring and supervision are critical for identifying and addressing compliance issues. The survey revealed:

• 55.6% of respondents have monitoring and supervision processes

• 33.3% do not have such processes or lack a clear approach

• 11.1% are unsure

While a majority have monitoring processes in place, the need for clearer approaches at several firms suggests room for improvement.

5. Resourcing

Adequate resources are necessary for implementing and maintaining strong compliance practices. Respondents reported:

• 55.6% believe they have adequate resources

• 33.3% do not have adequate resources

• 11.1% are unsure about their resourcing

Over a third of respondents feel they need more compliance support, which is concerning and may contribute to gaps in other areas.

6. Capability and Competence

Having capable and competent staff is crucial for effective compliance management. The survey found:

• 66.7% of respondents believe their teams are capable and competent

• 22.2% of respondents think they “do ok” despite not having full capability

• 11.1% of respondents are unsure

While most firms express confidence in their team’s capabilities, the uncertainty and acknowledged gaps at some firms suggest a need for further training and development.

7. Regulatory Change Management

Adapting to regulatory changes is essential in the dynamic financial services environment. Responses indicated:

• 55.6% of respondents have processes for managing regulatory change

• 33.3% of respondents “do ok” without formal processes

• 11.1% of respondents do not have a process

Several firms’ lack of formal processes may leave them vulnerable to compliance gaps as regulations evolve.

8. Openness to Challenge

A culture that encourages open discussion and challenges to the status quo can help identify and address potential compliance issues. The survey revealed:

• 55.6% of respondents encourage openness and appreciate conflicting views

• 33.3% of respondents indicate that alternate views are ignored or discouraged
• 11.1% of respondents support a ‘team player’ mentality

Over a third of respondents report a lack of openness to challenge, which is concerning as it may inhibit the identification and resolution of compliance issues.

The fact that one-third of respondents report a need for more openness to challenge is concerning, as it may inhibit the identification and resolution of compliance issues.
Unusual Results and Areas of Concern


Several unusual results and areas of concern emerged from the survey:


1. Inconsistent Maturity vs. Practices:
Some respondents who described their businesses as ‘mature’ or ‘established’ reported significant gaps in basic compliance practices. This suggests that business longevity does not always correlate with strong compliance practices.
2. Experience vs. Role Mismatch:
One respondent in a senior risk and compliance role reported only 1-5 years of industry experience. This raises questions about the depth of compliance expertise in some firms.

3. Authorisation Discrepancy:
A respondent in a Risk/Compliance Officer role reported being not authorised to provide financial services. This seems inconsistent with typical industry practices and may indicate a misunderstanding of regulatory requirements or a gap in licensing.

4. Start-up with Strong Practices:
The ‘Start-up’ respondent reported having strong practices in place for most categories, which is somewhat unusual for a new business. This could indicate a particularly compliance-focused approach, a consequence of the licensing process or potentially overly optimistic self-assessment.

5. Institutional Licensee Challenges:
One institutional licensee reported several negative responses, including a lack of business improvement processes and openness to challenge. Although this might not be unusual for a larger organisation, it may indicate cultural or structural issues. 
6. Varied Approaches to Challenge:
Despite most respondents encouraging openness, a significant minority reported that alternate views are ignored or discouraged. This suggests potential cultural issues that could hinder effective risk management and compliance.