The purpose of the P&Ps is to help ensure a high level of client service, ensuring that the regulatory requirements are adhered to and whilst simultaneously minimising the business risk.

A policy is a set of general guidelines that outlines how the business will tackle something. It should be a link between the vision, values, risk appetite and the day-to-day operations. 

A procedure sets out the action plan for carrying out the policy, essentially a step-by-step instruction for how to complete a task. This is the final step in the policy, process and procedure implementation. A checklist can form a helpful step-by-step tool.

Which P&Ps are required will depend on the type of business, what services are being provided, and the regulatory status of the business. Once you have identified which P&Ps your business requires, you will need to identify who will prepare these.

Formulation
Virteffic can assist in drafting and/or enhancing the P&Ps in accordance with your requirement, gathering information, and conducting research. As part of the process, Virteffic will liaise with the appropriate stakeholders, including your compliance team, circulate the draft P&Ps for review, and update the same following receipt of any comments.

Implementation
Virteffic can also assist in co-ordinating the required board meetings (once the P&Ps are in agreed, final form) and present these to the board for their consideration before implementation.

Regulatory changes occur frequently. Building an effective regulatory mapping process is part of a business’s compliance program and is the mechanism for being aware of regulatory changes. It is an integral part of a registered person’s risk management framework, specifically in relation to compliance risk.

Virteffic can assist with the process of reading and analysing the regulatory text (such as laws, regulations, regulatory statements etc.).

Mapping
The compliance officer of a business will monitor regulatory websites, newsfeeds and other sources to identify the latest regulatory updates, additions and changes that apply to your business. Virteffic can assist in conducting the mapping exercise once the regulatory text has been identified.

Gap Analysis
Following the completion of the regulatory mapping, a gap analysis will need to be conducted to ensure that your business has implemented the required P&Ps and has adequate controls in place to mitigate any risks. Virteffic can assist in cross-referencing the P&Ps to the mapping schedule.

Virteffic can assist your compliance officer with some of the administrative tasks relating to the Compliance Monitoring Programme (CMP) and the assessment of a registered person’s adherence to applicable legislative and regulatory requirements and corresponding controls. With reference to the guidance notes issued by the JFSC, it can occur throughout the business. It need not be solely undertaken by the compliance function (e.g. the Compliance Officer, MLRO, MLCO, and staff who directly report to the individuals appointed to these Key Person positions).

We can assist with the various steps in the cyclical process of compliance monitoring, including:

• identifying relevant legislative and regulatory requirements;
• identifying relevant controls (which would include the policies and procedures);
• assisting with the CMP tests and reporting; and
• overseeing remedial actions. 

Evaluation
The P&Ps should be evaluated to ensure they are aligned with the aim and requirements initially identified, following which they were prepared. The P&Ps should then be reviewed on a regular basis to ensure they continue to meet the requirements of your business and regulatory requirements. Virteffic can assist your compliance officer in reviewing your P&Ps, cross-reference these against the requirements, and assist with any updates required.

Reporting
An update should be provided to the Board to include a report on tests and findings. In addition, regular updates should be provided to the Board in regards to the status of the testing against the annual CMP plan and also with regards to the status for clearing any outstanding findings and implementation of any enhanced controls (if required). Virteffic can assist in preparing the reports. Virteffic can also assist with organising the board meeting and preparing the minutes.

The corporate governance calendar, also known as a board calendar or agenda planner, is an annual plan of items that require the board’s (or committee’s) attention. It is useful to make sure that sufficient time is allocated for all the essential fiduciary, strategic, regulatory and board development items and that no mandatory items are missed during the year.

We can assist with the preparation of a Corporate Governance Calendar for your organisation and help identify the key events and requirements throughout the course of a year in your jurisdiction.

Contact us to learn more about how Virteffic can support your companies and organisations.

Virteffic has a team of qualified chartered secretaries and experienced individuals who can help to draft the minutes for your compliance, risk and new business acceptance committees. We will always prepare the minutes efficiently, professionally, and promptly, and with the utmost confidentiality.  The services offered by Virteffic include:

• attend meetings and assist your company secretary¹ with drafting the minutes;
• prepare minutes from recordings;
• preparing notices and agendas;
• co-ordinate the meetings; and
• summarise and circulate action points in accordance with an agreed timeline.

Get a fee quote – We can offer a fixed fee quote for minutes and meetings once you have confirmed the number of meetings and the approximate length of each meeting.

¹ Virteffic will not accept an appointment as the Company Secretary as Virteffic does not provide any regulated services, or activities which would require us to be a “registered person” under and as defined in the Financial Services (Jersey) 1998, as amended.