HEALTH-CHECK / PRE-ATTESTATION REVIEW:
The SMCR requires that Senior Managers take “reasonable steps” to:
- Control the business effectively
- Comply with regulatory expectation
- Delegate authority to competent people
- Disclose bad conduct or reckless behaviour to the Regulators (‘Whistleblowing Clause’)
Lysis can assist with:
- Firm-wide governance and risk management review.
- Deep-dive review of a specific business/operational unit to assess its processes and controls.
- Recommendation and implementation of improvements prior to a manager attesting.
In order to enable Senior Managers to attest that their areas of responsibility are being conducted properly and are compliant with all necessary laws the firm will need to invest time in making sure that processes are properly mapped and understood and that controls are effective. This will be a particular challenge where parts of a process are outsourced to a third-party or executed by another group entity.