The old joke about “How do you eat an elephant? – one bite at a time!” can be applied to compliance issues as well: dealing with them department-by-department within the firm is one way of breaking down the problems into bite-sized chunks. That may seem
to make the problems more manageable, but in reality regulators don’t look at whether individual departments achieve regulatory compliance: they look at the firm as a whole. That’s particularly relevant to overarching firm-wide compliance issues such, as
the “information creep” that can happen through Chinese walls and between departments, and that can potentially lead to market abuse.
Getting an overview of how information flows through and across the firm is never easy: if you limit your view to an individual department, you too easily find yourself in a situation where you can’t see the forest for the trees. The complex nature of the
firm’s operations means that you have to take a step back to get a true three-dimensional view of those operations and information flows. Only then can you start to see which information will need to be centralised, and which can remain to be handled by departments,
in order for regulatory compliance to be monitored effectively.
Sometimes a firm can get into a state of “paralysis through analysis”: multiple departments can see the benefits to each of them of a particular toolset but none of them can individually make a decision on behalf of all departments. Taking that step back
allows a Global Compliance Officer to see where common tools and approaches can be used across multiple departments, enabling the firm to implement the right tools to do the job while at the same time achieving cost-efficiencies across the broader business.
When you’re faced with three-dimensional, company-wide compliance issues, it’s critical to have toolsets that give you a 3-D view of the firm and the market that you operate in.