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INSIGHTS
Are you thinking about your Compliance initiatives strategically ?

                                  From surviving to thriving
                                  Compliance related fines totalled more than $3.5bn in 2012. Financial sector compliance has
                                  moved from the business pages to the front page. LIBOR, regulations, capital adequacy, anti-
                                  money laundering and other industry terms are becoming discussed as regularly as last week’s
                                  football results.

                                  We’ve observed in many clients that when people speak about compliance it tends to be
                                  reactive – a problem has been identified and it needs to be fixed. Businesses tend not to see
                                  compliance in a strategic fashion as it has traditionally been a cost centre that has not
                                  contributed to the bottom line. A seismic perception shift needs to occur – compliance needs to
                                  be seen as a strategic opportunity.


                                  Surviving, th riving and playing the long game
                                  The FSA has published a short guide that assists organisations with selecting compliance
                                  consultants1. The first aspect addressed is how one should go about establishing one’s needs.
                                  The questions asked can be summarised as follows:
                                           Do you have an area of concern or weakness and require a compliance audit?
                                           What level of support do you require or are there specialist areas with which you
                                            require help?

It is essential to consider       We believe that there is more that should be considered. Not only is it essential to understand
    whether a compliance          why the organisation has any need for a compliance engagement, it is also essential to
                                  consider whether there are broader strategic opportunities that can be created.
       initiative presents a
          broader strategic
                                  Why am I in this position?
                opportunity
                                           One of the reasons may well be because you have an area of concern or weakness, a
                                            reactive need (Surviving) …
                                        … but it may be because new legislation is on the horizon, or you have a desire to
                                         introduce rigour into your processes. These two aspects (and many others) move
                                         organisations from the reactive to the strategic space, and the compliance initiative
                                         becomes an opportunity rather than simply reducing risk (Thriving).
                                  Where do I want to be after this compliance initiative?
                                           Reactive compliance initiatives aim to make sure that an organisation is compliant
                                            with the relevant regulatory body. The main aim is to keep your trading license
                                            (Surviving).
                                           Strategic compliance initiatives allow for the creation of competitive advantages that
                                            enhance both market and customer reputations. It’s about creating new opportunities
                                            to allow your business to take the initiative rather than to wait and defend (Thriving).

                                  Well known leadership author Stephen Covey talks about different quadrant behaviours 2. An
                                  analogy for quadrant behaviours is the difference between putting out fires (quadrant 1, Q1)
                                  and mitigating the spread of fire by cutting firebreaks (quadrant 2, Q2). Q2 activities feel less
                                  urgent but, more often than not, reduce the need for Q1 activities. The same analogy can be
                                  applied to how budget and effort is allocated across compliance projects.


                                  1 - http://www.fsa.gov.uk/smallfirms/resources/factsheets/pdfs/factsheet_consultant.pdf
                                  2 - Covey introduces this idea in The Seven Habits of Highly Effective People & details them further in First Things First




                      Business Systems Group (UK), Registered in England No. 6150570, 230 City Road, London, EC1V2TT
                                                            www.bsgdelivers.com // @bsguk

             This document can only be reproduced in its entirety. This document does not constitute any form of advice from BSG (UK).
INSIGHTS
 Are you thinking about your Compliance initiatives strategically?

    Firefighting is merely       Our observation is that currently a lot of compliance initiatives are Q1 activities – projects to
  about surviving, there’s       “fix up” process gaps, gather new pieces of data, etc. This short-term approach ticks the
                                 current box, but doesn’t structurally improve the organisation’s ability to meet changing
  no long-term structural        compliance regulations. A “thriving mindset” demands that we spend more time on Q2
                   benefit       activities to introduce flexibility into the overall business system, allowing the organisation to
                                 be better prepared to meet changing compliance regulations.

                                 Get ahead of the game – start taking those strategic
                                 opportunities
        Thriving demands         It is an unfortunate reality that budget for compliance initiatives is typically allocated to Q1
       thinking about the        type projects, taking a surviving mindset. If this budget were to be, at least in part, dedicated
                                 towards more Q2 initiatives, then problems will be spotted early enough for their impact to be
     future and preparing        mitigated and similarly, opportunities will be identified soon enough for them to be exploited.
               accordingly
                                 It is a significant challenge to ensure that a Q1 thinking culture doesn’t become pervasive in
                                 responding to the ever-changing compliance landscape. Convincing board colleagues that a
                                 compliance initiative represents an opportunity may be difficult, but will ultimately prove
                                 rewarding.

                                 Building a case for a broader perspective can be done by adopting a typical business analyst’s
                                 process worldview. Take a step back and look at the whole situation, at both the upstream and
                                 downstream implications of the problem. Conduct root cause analysis to get to grips with what
                                 is manifesting itself in the shape of the problem. Make this insight part of the information pack
                                 provided to decision makers. Inform them that in fixing the current problem, if we also analyse
                                 certain other areas we will be able to identify inefficiencies and thus improve overall
                                 profitability in a number of ways.

                                 Driving forward into Q2
                                 Q1 activities will never go away, but we feel that spending 100% of your time on these
                                 activities is not sustainable. Q2 behaviour generates understanding, perspective and clarity,
                                 likely resulting in fewer crises. In short, fortune favours the prepared. Organisations that move
                                 their compliance activities towards this quadrant will generate more benefit from compliance
                                 spend making it easier to both take advantage of business opportunity and respond to new
                                 compliance requirements.

                                 Make no mistake that moving from surviving to thriving will require a cultural shift within
                                 your organisation. For years organisations have been reacting to compliance changes. By
                                 driving this cultural shift you will notice that your organisation will become more visionary
                                 and less reactive, and in today’s ever-changing compliance landscape being on the front foot
                                 can only be a good thing.

                                 A long term culture of proactively analysing the regulatory landscape will allow companies to
                                 continually innovate in this space and not only be first to implement regulatory compliant
                                 processes but also the first to market with the most rigorous, efficient and effective processes

At BSG we are passionate
about design and delivery        BSG (UK)
  of change that makes a
                                 We’ve observed that compliance projects are often maligned as mere tickbox exercises. By
        difference for our       contextualising the projects and understanding the opportunities they offer, we believe that
      customers and their        compliance is both interesting and important. We talk about this in more detail at
               customers.        http://bit.ly/cancompliancebeinteresting


          A collection of BSG (UK) BA practitioner                                                          www.bsgdelivers.com // @bsguk
          insight can be found at                                                                                        +44 20 3416 6400
          http://bit.ly/bsgukinsight                                                                                    info@bsguk.co.uk


                      Business Systems Group (UK), Registered in England No. 6150570, 230 City Road, London, EC1V2TT

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BSG (UK) Thinking strategically about compliance version 1

  • 1. INSIGHTS Are you thinking about your Compliance initiatives strategically ? From surviving to thriving Compliance related fines totalled more than $3.5bn in 2012. Financial sector compliance has moved from the business pages to the front page. LIBOR, regulations, capital adequacy, anti- money laundering and other industry terms are becoming discussed as regularly as last week’s football results. We’ve observed in many clients that when people speak about compliance it tends to be reactive – a problem has been identified and it needs to be fixed. Businesses tend not to see compliance in a strategic fashion as it has traditionally been a cost centre that has not contributed to the bottom line. A seismic perception shift needs to occur – compliance needs to be seen as a strategic opportunity. Surviving, th riving and playing the long game The FSA has published a short guide that assists organisations with selecting compliance consultants1. The first aspect addressed is how one should go about establishing one’s needs. The questions asked can be summarised as follows:  Do you have an area of concern or weakness and require a compliance audit?  What level of support do you require or are there specialist areas with which you require help? It is essential to consider We believe that there is more that should be considered. Not only is it essential to understand whether a compliance why the organisation has any need for a compliance engagement, it is also essential to consider whether there are broader strategic opportunities that can be created. initiative presents a broader strategic Why am I in this position? opportunity  One of the reasons may well be because you have an area of concern or weakness, a reactive need (Surviving) …  … but it may be because new legislation is on the horizon, or you have a desire to introduce rigour into your processes. These two aspects (and many others) move organisations from the reactive to the strategic space, and the compliance initiative becomes an opportunity rather than simply reducing risk (Thriving). Where do I want to be after this compliance initiative?  Reactive compliance initiatives aim to make sure that an organisation is compliant with the relevant regulatory body. The main aim is to keep your trading license (Surviving).  Strategic compliance initiatives allow for the creation of competitive advantages that enhance both market and customer reputations. It’s about creating new opportunities to allow your business to take the initiative rather than to wait and defend (Thriving). Well known leadership author Stephen Covey talks about different quadrant behaviours 2. An analogy for quadrant behaviours is the difference between putting out fires (quadrant 1, Q1) and mitigating the spread of fire by cutting firebreaks (quadrant 2, Q2). Q2 activities feel less urgent but, more often than not, reduce the need for Q1 activities. The same analogy can be applied to how budget and effort is allocated across compliance projects. 1 - http://www.fsa.gov.uk/smallfirms/resources/factsheets/pdfs/factsheet_consultant.pdf 2 - Covey introduces this idea in The Seven Habits of Highly Effective People & details them further in First Things First Business Systems Group (UK), Registered in England No. 6150570, 230 City Road, London, EC1V2TT www.bsgdelivers.com // @bsguk This document can only be reproduced in its entirety. This document does not constitute any form of advice from BSG (UK).
  • 2. INSIGHTS Are you thinking about your Compliance initiatives strategically? Firefighting is merely Our observation is that currently a lot of compliance initiatives are Q1 activities – projects to about surviving, there’s “fix up” process gaps, gather new pieces of data, etc. This short-term approach ticks the current box, but doesn’t structurally improve the organisation’s ability to meet changing no long-term structural compliance regulations. A “thriving mindset” demands that we spend more time on Q2 benefit activities to introduce flexibility into the overall business system, allowing the organisation to be better prepared to meet changing compliance regulations. Get ahead of the game – start taking those strategic opportunities Thriving demands It is an unfortunate reality that budget for compliance initiatives is typically allocated to Q1 thinking about the type projects, taking a surviving mindset. If this budget were to be, at least in part, dedicated towards more Q2 initiatives, then problems will be spotted early enough for their impact to be future and preparing mitigated and similarly, opportunities will be identified soon enough for them to be exploited. accordingly It is a significant challenge to ensure that a Q1 thinking culture doesn’t become pervasive in responding to the ever-changing compliance landscape. Convincing board colleagues that a compliance initiative represents an opportunity may be difficult, but will ultimately prove rewarding. Building a case for a broader perspective can be done by adopting a typical business analyst’s process worldview. Take a step back and look at the whole situation, at both the upstream and downstream implications of the problem. Conduct root cause analysis to get to grips with what is manifesting itself in the shape of the problem. Make this insight part of the information pack provided to decision makers. Inform them that in fixing the current problem, if we also analyse certain other areas we will be able to identify inefficiencies and thus improve overall profitability in a number of ways. Driving forward into Q2 Q1 activities will never go away, but we feel that spending 100% of your time on these activities is not sustainable. Q2 behaviour generates understanding, perspective and clarity, likely resulting in fewer crises. In short, fortune favours the prepared. Organisations that move their compliance activities towards this quadrant will generate more benefit from compliance spend making it easier to both take advantage of business opportunity and respond to new compliance requirements. Make no mistake that moving from surviving to thriving will require a cultural shift within your organisation. For years organisations have been reacting to compliance changes. By driving this cultural shift you will notice that your organisation will become more visionary and less reactive, and in today’s ever-changing compliance landscape being on the front foot can only be a good thing. A long term culture of proactively analysing the regulatory landscape will allow companies to continually innovate in this space and not only be first to implement regulatory compliant processes but also the first to market with the most rigorous, efficient and effective processes At BSG we are passionate about design and delivery BSG (UK) of change that makes a We’ve observed that compliance projects are often maligned as mere tickbox exercises. By difference for our contextualising the projects and understanding the opportunities they offer, we believe that customers and their compliance is both interesting and important. We talk about this in more detail at customers. http://bit.ly/cancompliancebeinteresting A collection of BSG (UK) BA practitioner www.bsgdelivers.com // @bsguk insight can be found at +44 20 3416 6400 http://bit.ly/bsgukinsight info@bsguk.co.uk Business Systems Group (UK), Registered in England No. 6150570, 230 City Road, London, EC1V2TT