Regulatory Compliance

The program, not the policy binder.

Counselize builds and reviews the compliance programs regulated businesses are required to operate, and supports them through examinations, regulator inquiries, and remediation.

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Every supervised business is expected to operate a compliance program, and the expectation is not a document. It is a set of controls that runs, produces evidence, and can be examined. A purchased policy set that does not describe what the business actually does is worse than none at all, because it establishes the standard the examiner will then measure against.

A program is built from a risk assessment specific to the products, customers, geographies, and channels involved, written policies and procedures that follow from it, a designated officer with real authority and access to senior management, training, monitoring and testing, escalation and reporting, and independent review. Anti-money-laundering programs carry the additional statutory elements of customer identification and due diligence, sanctions screening, transaction monitoring, and suspicious activity reporting.

Programs are tested in two ways. Examinations and regulator inquiries ask a business to demonstrate what it has been doing, usually on a short timetable and through a document request that is itself a diagnostic. Regulatory change asks whether anyone noticed a new rule in time to act on it. Both go better with a record already assembled than with one reconstructed after the request arrives.

Where a review or an examination identifies gaps, the work is remediation planned in an order that reflects risk, with the corrective record documented as it happens rather than described afterward. Counselize conducts independent reviews and testing, and, so that the independence means something, does not perform that review on a program it built for the same client.

Scope

What this covers.

01Program designCompliance program design and gap assessment against the requirements that actually apply, with a build sequence ordered by risk rather than by ease.

02Risk assessmentEnterprise and product-level risk assessments covering products, customers, geographies, and delivery channels, documented so the program's design traces back to them.

03Policies and proceduresWritten policies, operating procedures, and control documentation that describe what the business does, in a form an examiner can follow.

04AML and BSA programsProgram development including customer identification, customer and enhanced due diligence, sanctions and OFAC screening, transaction monitoring and alert governance, and suspicious activity reporting procedures.

05Consumer complianceFair lending and unfair or deceptive acts and practices compliance, marketing and disclosure review, and complaint handling and escalation procedures.

06Governance and trainingCompliance officer designation and charters, board and senior management reporting, escalation paths, and training programs for the people who operate the controls.

07Independent review and testingIndependent AML program reviews, compliance testing and monitoring plans, and the findings record that supports them.

08Examinations and inquiriesExamination preparation, document request responses, regulator inquiries and information requests, and the communications record kept throughout.

09RemediationRemediation planning ordered by risk, corrective action records built as the work happens, and validation that the fix holds.

10Regulatory change managementA process for identifying rule changes that affect the business, assigning them, and evidencing what was done in response. Includes Corporate Transparency Act beneficial-ownership reporting.

Independence in a review is only real if it is structural. Counselize does not perform independent testing of a compliance program that it designed or implemented for the same client, and says so at intake rather than at the end.

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