Knowledge Base
Assess the effectiveness of an organization's ethics policies and procedures
What is the starting point of the risk-based approach for evaluating the effectiveness of ethical policies?
According to the text, non-compliance risk mapping is the starting point. It involves identifying applicable regulatory obligations, assessing risk exposure, evaluating the effectiveness of control mechanisms, and determining residual risk. This step is crucial because it structures the entire evaluation methodology.
What is a best practice identified by the AMF's SPOT reviews?
The AMF's SPOT reviews identify several best practices, including a dedicated committee structure (regular compliance committee), the RCCI reporting to senior management, and a clear separation between permanent and periodic control. These practices strengthen the effectiveness of the ethical framework.
What elements must the strategic-level compliance dashboard present?
The strategic dashboard includes a summary of major risks, the evolution of key indicators, significant incidents, a benchmark of sanctions and budget monitoring. These elements help senior management make informed decisions.
What elements must the non-compliance risk mapping include?
The risk mapping must include several key elements: identification of regulatory obligations, assessment of risk exposure (probability multiplied by impact), evaluation of the effectiveness of control mechanisms, determination of residual risk, and prioritisation of actions. These elements are essential for a complete and regular assessment.
The permanent control plan must be updated only when there are significant changes in activity or regulation.
The text specifies that the risk mapping must be updated at least annually, or upon any significant change in activity or regulation. This means that the annual update is mandatory, even in the absence of significant changes.
Categorize items by dragging them to the appropriate zones
Items to categorize:
Permanent control
Periodic control
Permanent control includes thematic and sample-based controls, while periodic control includes internal audits. This distinction is crucial for understanding the overall compliance framework.
Control plan execution rate (target)
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The text indicates that the control plan execution rate must be above 95%. This indicator is crucial for measuring the effectiveness of the permanent control system.
AMF decision SAN-2025-10 sanctioned an organisation for a non-existent or inadequate AML/CFT risk mapping.
The text mentions that this decision imposed fines for typical deficiencies, including a non-existent or inadequate AML/CFT risk mapping. This underlines the importance of a complete and up-to-date risk mapping.