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(RE)IMAGINE

The Official Blog of Acuity Knowledge Partners


INVESTMENT COMPLIANCE – WHY NEEDED, TRENDS AND BEST PRACTICES

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Published on February 2, 2024 by Ranjith Poojary and Sandeep Khandelwal

What is investment compliance?

Investment compliance (IC) is an important aspect of portfolio management.
Portfolio managers (PMs) must ensure that their portfolios comply with the
regulatory requirements and policies of particular committees and clients in
accordance with investment agreements.

Why asset management firms need to monitor investment compliance

Proactive monitoring is crucial to ensure managers keep abreast of the evolving
regulatory guidelines in order to mitigate risk and avoid penalties and
reputational loss. Organisations often update their policies, and managers
should be diligent about staying on top of these changes and their impact on
accounting practices. When a violation is identified, it should be rectified
within the stipulated timeframe; this would reduce the financial and legal
consequences for both investment managers and clients.

Recent data shows that the number of investment advisors has grown by about 50%
over the past 10 years. Investment managers from international asset management
companies work with investors from a number of countries. Investments in these
countries are governed by different regulatory bodies and local laws. To be
compliant with these regulations and laws, investment managers should have
sufficient knowledge of regional regulation.

Despite their best efforts, asset management companies face significant
pressure. Recent developments in the investment sector and regulators’ efforts
to enforce policies have made the compliance environment more challenging, and
monitoring compliance is key to navigating this.

The need for investment compliance

The following illustrates what compliance involves.



The 2008 financial crisis led to an increase in regulatory scrutiny. The role of
the compliance department shifted from providing advice to active risk
management and monitoring. Compliance departments are now expected to provide
practical perspectives on translating regulations into operational requirements.

The role of investment compliance is not only to ensure that a business is
compliant with external regulations and client mandates, but also to maintain
internal controls and standards. In the financial services sector, compliance
departments ensure that regulatory objectives are met to protect investors and
that markets are fair, efficient and transparent.

Investment compliance mainly relates to pre-trade, post-trade and end-of-day
batch monitoring, along with account management functions. The investment
compliance function not only provides advisory solutions for compliance
breaches, but also notifies PMs of issues that require immediate attention.

Major trends in investment compliance

Amid the rapid growth of the compliance sector and constant change in
regulations, new technologies and tools are being developed to streamline the
process.

We list some compliance-related trends in the financial sector below:

1. Sanctions

A number of countries have imposed sanctions on Russia and Belarus since the
start of the Russia-Ukraine war. There are also sanctions on countries such as
Iran and Sudan and Chinese military companies, directly prohibiting investing in
their securities. Organisations should be vigilant enough to ensure that their
clients are protected from exposure to such sanctions.

2. ESG

Environmental, social and governance (ESG)-related investments are increasing,
leading to companies becoming more conscious about their impact on the
environment and society and starting to offer ESG-focused products.

3. Due diligence

Enhanced due diligence plays an important role in identifying money laundering
and fraud and in reviewing the policies and procedures of an organisation. The
higher risk associated with sanctioned entities necessitates additional checks,
including advanced searches, transaction monitoring and fund verification and
generating intelligence reports on the customer or business owner.

4. Technological advancements

Seventy-six percent of the compliance managers surveyed say they manually scan
regulatory websites to track changes and assess the impact on their
organisations, according to the MetricStream State of Compliance Survey Report
2021. Technological advancements and the adoption of machine learning have led
to an increase in the development of in-house compliance tools to automate the
different investment compliance functions.

5. Fines and penalties

The US Securities and Exchange Commission (SEC) imposed a record-breaking
USD6.4bn in penalties and disgorgement in 2022. Organisations could lose
millions in revenue due to a single non-compliance event. Organisations spend
USD5.47m on compliance compared to an average of USD14.82m for non-compliance
(source: GlobalScape).

Best practices for investment compliance

Organisations face challenges in day-to-day operations while monitoring
investment compliance. Adhering to best practices would reduce operational
inefficiency and risk of non-compliance, and enhance the effectiveness of the
overall compliance structure.

 * Address every alert that is non-compliant and conduct a root-cause analysis
   before approving the alert. Save all related documents and correspondence for
   future reference.

 * Notify the PM of a red flag as a potential violation, so the necessary action
   could be taken to ensure that the fund remains compliant with the prescribed
   guidelines.

 * Reduce the number of false alerts by identifying rule-optimisation items or
   conducting a standard review of the restriction while coding in the system.

 * Make use of automated tools and formulated sheets where required to increase
   efficiency and reduce human error in monitoring. Focus on developing in-house
   tools to automate the account management process.

 * When launching a new account, interpret guidelines from the investment policy
   statement/prospectus properly and create grids and onboarding checklists. A
   secondary standard review would check for omissions and mistakes.

How Acuity Knowledge Partners can help

We are pioneers in investment services offerings. We create tailor-made dynamic
functions with a robust, responsive and proficient control framework and process
delivery. Our highly experienced tool-agnostic team provides support
in investment compliance, trade surveillance and corporate, forensic and crime
compliance. These services are supported by our proprietary suite of Business
Excellence and Automation Tools (BEAT), which offer domain-specific contextual
technology.

Our teams of experts have a unique combination of skillsets. They have extensive
experience in order management/compliance systems such as Bloomberg AIM, Ion’s
Latent Zero Sentinel, Charles River Database (CRIMS), LDC, ThinkFolio and
BlackRock’s Aladdin, BTCA and SMARTS.

Sources:

 * Global risk and compliance report 2021 | Refinitiv

 * SEC.gov | SEC Announces Enforcement Results for FY22

 * State of Compliance Survey Report 2021 (metricstream.com)

 * Why Investment Compliance Monitoring is Critical | Finreg E (finreg-e.com)

 * Investopedia

Tags:

account management functions Asset Management compliance department due
dilligence Investment Advisors Investment Compliance Monitoring



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ABOUT THE AUTHORS

Ranjith Poojary

Know More

Ranjith Poojary has over 9 years total work experience, and is currently working
as an investment compliance specialist in pre-trade, post-trade monitoring and
rule coding. He has worked for firms including Oracle & State Street Syntel. His
expertise spans across the Portfolio risk analytics and investment compliance
sector. At Acuity Knowledge Partners he is working as a Delivery Lead supporting
both post & pre-trade compliance services. Ranjith has done his MBA from Acharya
Institute of Technology, Bangalore.

Sandeep Khandelwal

Know More

Sandeep has overall 14+ years of experience and is currently working as
Investment compliance specialist in pre trade & post trade monitoring. He has
worked with various firms including BNY Mellon Pershing, Standard Chartered Bank
& HDFC Bank. His expertise spans across Retail Banking operations, Capital
Market Operations & Compliance monitoring. At Acuity Knowledge Partners, he is
working as a Delivery lead supporting both post & pre-trade compliance services.
He is a MBA graduate in Finance from GRD College of Management, Coimbatore.

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