Category Archives: Remedial Compliance Risk Management

Getting Ready For The 6AMLD

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aml specialist consultants londonThe sixth anti-money laundering directive (6AMLD) is almost here. It has been n effect in EU member states since December 3, 2020, all financial institutions must implement the directive by June 3, 2021.

While there are fewer big changes than previous directives, 6AMLD brings clarity to specific regulatory details to close loopholes, toughen penalties, and encourage greater cooperation. Its goal is to empower financial institutions and states to do more in the fight against money laundering and the financing of terrorism.

UK financial services businesses

The UK has chosen to opt-out of abiding by further AML policy as the Government believes that domestic legislation is already mostly compliant with the Directive’s steps and, in most cases, goes even more than what 6AMLD proposes. For example, in the UK, the maximum penalty for money laundering is fourteen years, going beyond the new four-year minimum needed by 6AMLD; and aiding and abetting offenses of helping, motivating, and trying to launder money is currently a criminal matter.

However, it is essential to keep in mind that UK-based businesses in the monetary sector that operate within the EU jurisdiction will require to comply with the modifications set out in 6AMLD.

Access to clean and available international customer data for effective AML/ KYC screening

To be ready for 6AMLD, those in financial services require to know their clients, whoever they are. The key is to have access to billions of consumer records worldwide from trusted data streams; these consist of federal government firms, credit firms, and energy records for cross-check and verification purposes. It is particularly essential to obtain confirmation of important proof of address. Having access to up-to-date watch lists, such as politically exposed Persons (PEPs) information as part of this dataset is likewise essential.

From a customer experience perspective, the checks leveraging this data should take place in real time to prevent slowing the consumer onboarding procedure. This data should also originate from a single source to avoid the requirement for many expensive providers in various markets. This issue frequently results in irregular ID data and supply chain management issues.

Regtech: MRZ and ORC ID document scanning and biometrics to support 6AMLD compliance

When it pertains to remote onboarding, banks need to use machine legible zone (MRZ) and optical character recognition (OCR) innovations to gather customer ID and extract important details. This ensures the ID is real and validated in real time. The image ID embedded in these scanned documents supports biometric ID confirmation, such as facial acknowledgment, which can likewise help securely speed up consumer engagements.

Nevertheless, the biometric innovation must provide liveness checks, such as eye motion, for proof of life confirmation. This is vital with scammers significantly utilizing creative approaches like 2D images and video playback to try to trick facial recognition technology and ‘prove’ they are the person they are impersonating. In fact, this process can result in money services (MSPs) and Payment Service Providers (PSP) organisations getting a due diligence report related to AML and KYC that can be used to show their compliance when it comes to regulatory checks.

To prevent money being laundered and prevent extreme sanctions, financial services companies operating within the EU needs to comprehend and be ready for 6AMLD by the June due date. Ideally, this must involve having access to billions of consumer records worldwide for cross-check and ID confirmation functions, helping recognize individuals throughout borders. They must also undertake document scanning with MRZ and ORC innovation, which will also allow delivery of biometrics that help to safely speed up engagement with customers. Embracing these procedures will decrease the concern of compliance and equip financial institutions for more stringent global policies in the future.


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Why Is Document Version Control So Important?

Why Is Document Version Control So Important?

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Why is Version Control Important?

Version control is important when documents are being created, and for any records that undergo a
lot of revision and redrafting or annual reviews. It helps us to track changes and identify when key decisions were
made along the way. It is particularly important for electronic documents that are being reviewed
by a number of different users.

Knowing which version of a document you are looking at is important if you are trying to find out which version of a policy is currently in force, or which version of a policy was in use at a particular time. It forms good records keeping practice which is particularly important in meeting our obligations under the Freedom of Information Act.

The aim of this document is to provide best practice guidance for applying version control to
different types of document at the University of Nottingham. This guidance covers best practice use
1. File Naming conventions
2. Version Numbers
3. Version Control Tables
4. Document control Tables

File Naming Conventions
At the simplest level you can use file naming conventions to identify the version of a document. Use
the file name of the document to determine both the version and status alongside the subject , for

Records Management Policy Draft v0.1

Records Management Policy Draft v0.3


Records Management Policy v1.0

Records Management Policy v1.1 (note: first revision – minor)

Records Management Policy v2.0

Remember to update the version number on the file name as well as the header (or footer) of the
document itself. It is easy to update a document and forget to rename the version number on either
the file name or the document which can lead to confusion.

Unless you don’t need to keep previous versions of the document, always save updated versions as
‘Read-only’ tag to ensure you are forced to create a new version the next time to go to update it.

File naming conventions alone will not tell you who made the change and what the change was. If it
is important to record this information use a version control table.

Version Numbers
Version numbering helps to distinguish one version of a document from another. For some
documents, you may decide that a simple numbering system consisting of consecutive whole
numbers is sufficient to help you keep track of which version you are working on. However,
documents that go numerous stages of development before a final version is reached, and for those
that are developed through input by multiple individuals, you may decide to adopt version numbers
to keep track of both minor and major changes to that document.

Minor Revisions
Minor revisions are small changes made to a document such as spelling or grammar
corrections, and other changes that… Minor revisions to a document are reflected by making
increments to the decimal number.

Major Revisions
Major revisions are changes to a document that require the document to be re-approved
(either by an individual or a group). Major revisions are reflected by incrementing the whole
number by 1.

document control version control

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document control version control

Remember – when electronically storing documents, it is often best practice to include the date at the front in reverse, as computers store files incrementally. So – 1st March 2021 becomes 20210301.


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This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

PSD2 Guide To Safeguarding & Wind Down Planning

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    Treating Customers Fairly – TCF Checklist

    Treating Customers Fairly – TCF

    Treating Customers Fairly TCF Checklist

    The FCA no longer carries out TCF specific visits, however this does not mean that they think it is any the less important. It does mean that by now they expect the principles of TCF to be embedded in all firms and to be the bed rock of their business models. The principle is to ‘put the customer first’ in everything which we do. Therefore, if during a visit or an interview they get the impression that TCF is no longer a priority, they will certainly investigate further and this is where you will need FCA compliance consultant by your side.

    TCF applies to both Product Providers and Intermediaries. Broadly, the Regulator intends that:

    Product Providers should ensure that:
    • their products are appropriately designed for the target market
    • the marketing material is clear, fair, not misleading, and likely to be understood easily by those reading it
    • the product should perform according to the expectations given
    An Intermediary’s primary responsibility is to ensure that:
    the customer has all appropriate information in an understandable format, which means;
    For advice sales:
    • the clients’ attitude to investment risk and capacity for loss has been properly established
    • the product is suitable for the customer
    • the product is affordable
    • the post sales service meets the expectations created
    The TCF exercise, which all regulated firms should undertake no less than annually, is essentially a “Gap Analysis.” For the purposes of Risk Management, the FCA expectations could be broken down into 6 key areas:
    1. Senior Management Responsibilities
    2. Communication with Clients
    3. The Advice Process
    4. The Post Advice Process
    5. Disclosure and Payment for Services
    6. Staff Competence
    The following is a non-exhaustive list for your guidance.
    The TCF Outcomes Management Statement
    • TCF is central to our corporate culture
    • Senior management can demonstrate how TCF is embedded in our business strategy
    • The fair treatment of customers is central to our Firm’s culture
    • Senior management practice what they preach and re-inforce TCF on a day to day basis
    • Senior management have undertaken a TCF audit / gap analysis
    • An action plan has been agreed and is/has been implemented
    • Critical elements of TCF are included within our MI. This is regularly reported and acted on
    • Staff routinely share best practice and can explain what TCF looks like to them
    • Adherence to TCF practices are rewarded
    • Remuneration policy and staff rewards support TCF
    • Actions taken demonstrate adherence to TCF obligations are recorded
    • Feedback processes are in place to gauge client satisfaction
    • Responsibilities for TCF are clear, e.g. for taking action, monitoring results / identifying improvement areas
    • Staff are engaged, motivated and trained in what TCF means
    • Everyone within the business is truly client focused
    • All our people are well trained for the roles they perform
    Products and services marketed….meet the needs of identified customer groups and are marketed accordingly 
    • Advisers are able to identify target markets for specific products
    • Financial promotions are regularly reviewed for relevance and clarity
    • Advisers/managers demonstrate their knowledge of products
    • The sign-off process for advertising and promotions is rigorous
    • We are confident in our expertise to recommend and manage in our chosen markets
    • Our promotions are targeted to ensure they are aimed at the right clients
    Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
    • TCF principles are reflected within T&C documentation, e.g. observation form
    • Content of documentation is not overly technical, e.g. suitability letter
    • Clients can clearly see the advice given and why, e.g. it isn’t buried in other documentation
    • Clients always understand the benefits of the advice / products recommended
    • Clients always understand the limitations and risks associated with the advice / products recommended
    • Documentation (such as suitability letters) are always tailored to individual clients
    Advice is suitable and takes account of their circumstances
    • Attitude to risk is clearly identified, understood by the client, documented, and matched by recommendations
    • Advice covers, where appropriate, non-income earning recommendations, e.g. National Savings, utilizing IHT annual allowance, repayment of debt
    • Soft facts are always collected on the fact find — not only what, but why?
    • Knowledge of adviser / supervisor products and associated advice areas is spot on —this is current and has been objectively assessed
    • There is no sales bias
    • Clients fully understand the status of the adviser and clearly understands the merits of the different remuneration methods
    • `Know your customer’ requirements are fully documented, e.g. limited advice or `client not prepared to disclose’ are the exception rather than the rule
    • We take time to understand our clients’ needs
    • We regularly review our stance on investment and technical issues
    • The fact find document readily captures all of the information we need about the clients circumstances for us to fully advise them.  
    Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect
    • Advice process includes a measurement of client satisfaction
    • Service standards (where agreed with a client) are met, e.g. time to write a report
    • Ongoing client reviews are always conducted as agreed with the client
    • Advice to existing clients is always the same as that to potential new clients, e.g. some advisers would not now recommend WP investments to new clients — what do we do about existing clients with WP investments?
    • Client reviews / contact methods are established with each client
    • Whatever client contact is agreed, this is followed through for both new and existing clients
    • Information is reviewed for relevance, accuracy, and clarity
    • Ensure clients expectations match provider service
    • Clients regularly complement us on our service
    Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint 
    • Complaints data / client feedback is reviewed to identify TCF issues
    • Staff and advisers know what a complaint is defined as and what to do when one is received
    • Service standards are in place and adhered to
    • Complaints investigated in a impartial manner without confrontation
    • Complaints processes in place and regularly reviewed (as applicable)
    • All client data is accurate, up-to-date, easy to use and accessible
    • Our database enables most client queries to be dealt with by support staff
    • Our software supports the main advice and business process

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    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

    FCA Regulatory Assessment Audit

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    Key Committee Meeting Minutes

    Key Committee Meeting Minutes

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    Committee minutes are important as they show the data and information available and presented, decisions made, responsibles for the actions agreed and timescales. Compliance Consultant will assess and grade the effectiveness and any errors, anomalies and inconsistencies for you to rectify your procedures.

    Plan your meetings effectively by
    • Setting dates well in advance to maximise the number of members available to attend (and sending a reminder notice);
    • Clarifying the purpose or focus of the meeting;
    • Ensuring that staff and financial reports are concise and comprehensible;
    • Ensuring conflicts of interest are declared;
    • Ensuring that minutes and agreed actions from the previous meetings are circulated.  Click here to download suggested format for Minutes;
    • Ensuring that all papers are circulated well in advance;
    • Agreeing the meeting agenda in advance.
    • Identifying which agenda items require a decision and which are for information or discussion; and
    • Purpose of meetings.
    • Planning your Management Committee meetings easier if the purpose of each meeting is clear.
    Management Committee meetings are for:
    • Monitoring and reviewing progress towards meeting the aims of the organisation;
    • Monitoring financial performance;
    • Ensuring all activities are consistent with the organisation’s purpose and mission;
    • Considering applications for membership of the organisation;
    • Planning annual general meetings;
    • Initiating and reviewing internal and external policy positions and statements;
    • Deciding on management and governance systems and processes;
    • Deciding the most appropriate methods of funding raising and considering applications for funding;
    • Delegating work;
    • Discussing and making decisions on new proposals;
    • Planning for the future and identifying new opportunities;
    • Delegating work; and
    • Deciding on appropriate staffing requirements, staff terms and conditions.
    • However, each individual meeting may focus on one or two issues.  Is there one or more development or proposal which requires a decision?  Should the financial report or the staff report be considered early in the meeting because it was at the bottom of the agenda at the last meeting and did not receive sufficient attention.
    A well planned agenda should clearly communicate the purpose and objectives of the meeting.
    Effective chairing
    Chairing is a key factor in the effectiveness of meetings.
    The role of the Chair is to direct discussion of the Committee, ensuring that the objectives of the meeting can be met, and that the Committee effectively fulfils its responsibility in consideration of the items on the agenda.  This involves ensuring that you are well briefed about each agenda item and that:-
    • decisions are taken, recorded and carried out;
    • the organisation’s policies are applied;
    • there is full participation;
    • the agenda is followed; and
    • there are time limits for the meeting as a whole and for agenda items.

    Meeting Minutes Best Practice

    Minutes should be including;
    1. Title of Meeting
    2. Date, Time, Venue
    3. People present
    4. Apologies for absence
    5. Conflicts of Interest
    6. Corrections to minutes of previous meetings
    7. Actions relating to previous meetings (sometimes referred to as matters arising)
    8. Items on the agenda
    9. Items to be discussed and decided
    10. Date, time and venue of the next meeting

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    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

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    Governance Risk & Compliance Frameworks

    Governance, Risk & Compliance Frameworks

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    Why is governance risk and compliance important?

    To ensure that businesses protect their information, have consistent cohesion departmentally, and follow all governmental regulations, a governance, risk and compliance, (GRC) program is important as new regulations can be overwhelming if a company doesn’t have a person or team to ensure updates are in place.

    What is GRC?
    Many people think of a platform when referring to GRC. But GRC refers to a capability that helps an organization achieve its objectives, with responsibility running right across the organization. GRC is a set of processes and practices that runs across departments and functions. GRC might be enabled by a dedicated platform and other tools, although this is not mandatory. While organizations generally don’t need to maintain a separate GRC department, most organizations have a team in place to manage the GRC platform and tools.
    What is the scope of GRC?
    By definition, the scope of GRC doesn’t end with just governance, risk, and compliance management, but also includes assurance and performance management. In practice, however, the scope of a GRC framework is further getting extended to information security management, quality management, ethics and values management, and business continuity management.
    What are the Elements of a GRC Framework?
    • Resources—required to conduct business, including strategies, policies, standards, procedures, organizational structure, roles and responsibilities, people, processes, technology, information, physical, financial and intellectual assets, and third parties (suppliers, vendors and contract employees).
    • Business attributes—the key attributes of a business include:
    • Performance, including goals, targets, outcomes, profitability and SLAs, etc.
    • Risk, including financial risk, credit risk, market risk, strategy risk, operational risk, fraud risk, reputational risk, information security risk, technology risk and compliance risk, etc.
    • Compliance, including regulatory compliance (SOX, PCI/DSS, GDPR), legal compliance (labor laws), organizational compliance (policies and standards), security (human, physical and information security), quality, ethics and values.
    • Governance, management, and operations—governance involves setting directions, optimizing risks and resources, and monitoring performance and compliance to achieve an organization’s objectives. It can be broadly classified into corporate governance, business governance, IT governance and legal governance. Management involves planning, organizing, leading, coordinating, controlling and reporting. Operations includes executing the process and function.
    • Controls—in order to realize value from the business, resources should be utilized efficiently and effectively, and business attributes should optimized. This is only possible when appropriate controls are implemented and executed. The controls can be classified as management controls, process controls, technical controls and physical controls. Controls are applied to the resources as well as the attributes.
    • Assurance—independent assurance is required to ensure that controls are designed and operating effectively, and compliance requirements are met consistently. It is the responsibility of governance to monitor and obtain assurance. Assurance will be primarily through audits. There are several types of audits. Internal and external audits, certification audits, financial audits, IT audits, compliance audits, process audits and security audits, etc.

    A good GRC Framework is reviewed periodically at monthly/quarterly reporting events to provide a complete audit trail of risk identification and awareness, risk management, understanding and mitigation and remedial plans. 

    It should consist of;
    Policies. Procedures and TORs for committees (inc BOD)
    Known Control Exceptions or Financial Crime breaches
    External Audit & Compliance Reports (Compliance Monitoring Plan Results)
    Risk Profiles and Appetite
    Summary of Existing Risks
    The Risk Register

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    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

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    Directors and/or Partners Responsibilities and Further Training

    Board of Directors – Understanding and Further Training?

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    Is it evident that the Directors understand:-
    • Directors’ liabilities and corporate governance
    • What is a company? What can it do?
    • What is a director? Types of director
    • Director’s responsibilities (SMCR & 
    • Internal governance
    • Corporate administration
    • Financial difficulties and investigations
    • General duties
    • Promoting the success of the company
    • Embedding duties
    • Reasonable steps (SMCR – See DEPP 6.2.9-E)
    • Legal context
    • Duty to act in good faith and with due care
    • Conflicts of interest
    Are there plans to enhance the board by:-
    • What will you do to improve your approach to governance and your role as a director?
    • What will be different about your next board meeting?
    • Board maturity
    • What do performance and success mean to your board?
    • Are there key messages / assumptions you need to challenge?
    • Do you have adequate succession plans in place?
    • What are your board’s future and legacy issues?
    • Action plans
    • Turning rhetoric into reality
    • Starting conversations to develop board and senior management team insight
    • Evaluating board and senior management effectiveness
    • Improving information flows between the board and the senior management team

    If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on 0207 097 1434 or email

    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

    SMCR Reasonable Steps – Step by Step

    SMCR Reasonable Steps – step by step

    The Duty of Responsibility

    Every Senior Manager has a Duty of Responsibility under the Financial Services and Markets Act 2000, which means that if a firm breaches one of the FCA’s many requirements, the Senior Manager responsible for that area could very well be held accountable if they failed to take reasonable steps to prevent or stop the breach. The Duty of Responsibility is designed to enshrine the move to individual accountability. But how?

    Regulatory action

    The Duty of Responsibility permits the FCA to take enforcement action against a Senior Manager Function (SMF) where it can demonstrate that:
    • misconduct occurred within the Senior Manager’s firm
    • at the time of the misconduct (or during any part of it), the Senior Manager was responsible for the management of any of the firm’s activities in relation to which the misconduct occurred
    • the Senior Manager did not take reasonable steps to avoid the misconduct occurring or continuing.
    Where the FCA wishes to take enforcement action against a SMF, the burden of proof in respect of each of these elements rests with the FCA. Regulatory action can range from suspensions to monetary penalties depending on the severity of the breach. In certain circumstances the FCA will take action against both the relevant SMF/s and the firm itself.
    For detailed review; the FCA explained in its July 2018 policy statement Final Guidance: the Duty of Responsibility for insurers and FCA solo-regulated firms (, the guidance at 6.2.9-E of DEPP (the Decision Procedure and Penalties Manual) provides a lengthy and expressly non-exhaustive list of considerations that the FCA will take into account in assessing whether a SMF’s actions were reasonable in all the circumstances.
    Demonstrating reasonable steps as a Senior Manager
    Despite the apparent breadth of reasonable steps and the multitude of decisions that could be taken, a Senior Manager’s initial consideration should be proportionality. A Senior Manager in a relatively small financial services firm will not be able to, and arguably will not be expected to, take certain actions by virtue of the resources available to them. A Senior Manager should therefore take stock of the resources, capacity and capabilities at hand as soon as possible to assist them in understanding the confines within which they are working.
    Following this assessment a Senior Manager can then begin to take steps, where needed, that are not only reasonable but appropriate and proportional to the area of the business for which they hold responsibility. A Senior Manager may wish to consider, depending on specific circumstances, taking some of the following measures:
    • For incoming Senior Managers, reading the outgoing Senior Manager’s handover note can be a quick way of getting an early impression of the challenges and potential issues pertinent to the business area.
    • Effectively challenging and scrutinising key decisions made by the Senior Manager’s team will help to show that the business area is not run unthinkingly. Offering a considered opinion on matters is an important step in showing that the decision-making process has been thoroughly thought through.
    • The plethora of Management Information (MI) can be unhelpful, but understanding which parts are relevant to the business area and prioritising them can be an effective way of capturing potential issues before they crystallise into something far worse. SMFs should be proactively reviewing relevant MI to help inform decision-making.
    • SMCR and the concept of individual accountability does not negate or diminish the need to delegate but equally, it does not absolve any SMF when the delegated task creates issues or control weaknesses. Where delegation is used, the SMF should maintain oversight of the task(s). This can include periodically set meetings, daily updates, logs or reports. Any delegation should be done in a clear manner so that there is no ambiguity as to which members of the team hold certain actions, tasks and deliverables and where the reporting lines exist.
    • Visibility of other business areas, which the SMF may not necessarily be responsible for, can be a useful way of understanding pertinent risks to the business as a whole. Working in a collaborative manner with other departments and SMFs can help identify issues (before they escalate) and potential solutions. A second pair of eyes can offer an objective view on matters and assist in deciding what further steps should be taken.
    • Independent assessment and appraisal can “benchmark” the status of the firm from a governance, risk and compliance perpective, don’t rely on retained services to do this automatically: often a fresh view can pay dividends.
    • A SMF should be prepared to escalate issues to other business areas, the relevant governance committees and, if the severity of the issue warrants, to board level.
    • All SMFs should be proactive in managing and escalating any resource and capability issues within their business area. If the lack of employees or gaps in knowledge is hindering their ability to effectively manage and mitigate risk, this will often prevent the SMF from taking reasonable steps.

    If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on 0207 097 1434 or email

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    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

    The Importance of Good Management Information (MI)

    The Importance of Good Management Information (MI)

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    The significance and requirement of excellent operational detail (volumes, speed, performance indicators, controls, tolerances etc.) are vital to successful management of business. To be able to consistently make efficient decisions, a series of records and measurements is needed, and if they ceased to be accurate or effective can significantly affect the ongoing stability, and profitability of an organisation leading to poor management decisions.

    The information can be found in many different forms depending on the business, cashflow and forecasts are obvious, but sales, staff turnover, sales activity, marketing results, supplier consistency can also be performance indicators needed to demonstrate the efficacy of the business. Many firms also use  elements of worker retention numbers or consumer satisfaction rates. Ultimately though the term suggests anything that can be used to aide in the secret choices that management need to make; nevertheless, that does not imply all details captured provide value, usefulness or are “good”.

    What makes the MI “great”?
    When thinking about whether the details obtained is in fact of a high quality and therefore any use to the business, there are the following 5 key points to consider.
    • Significance: Take into account whether the details you have is actually pertinent to the company, however likewise to the staff member who will be using it.
    • Authentic: To be able to utilise the information to make key decisions, it should really be authentic and precise info.
    • Trigger: If it takes too long to get, or too long to be provided to individuals who need it at the right time, then it would not be of any use, for that reason it is necessary the collection of data to be utilised is set over a specific period; you can’t compare apples with pears.
    • Pursued: For it to be great, then it should have the ability to be acted upon, if not then the time spent gathering was pointless.
    • Documented: If the information gathered has not been examined or analysed, processed and recorded, it will create huge issues for the firm in the future if they try ro reference back to the measure or effectiveness/accuracy of what was provided. Poor records make future decisions impossible to make effectively and this would fail the SMCR “Reasonable Steps” test for SMFs.
    Too much information and an avalanche of “performance indicators” is no use at all. Key Performance Indicators eed to be established and reviewed periodically (to ensure they maintain value). It is in combination of all these factors that comprise “good details”, however it depends on the management to choose which elements are more crucial that others, if there is an urgent requirement for information, then the weighting on the significance of it might eclipse the requirement for it to be documented, however this constantly depends on the environment, both from a business and regulatory perspective.
    Why is good management details crucial to a service?
    When the information utilised is of a high standard, it can allow a business to recognise areas for enhancement, or fine tuning keep track of the quality of operations, boost profits and evaluate strengths and weak points to enable time to be spent on doing what the company does best, and raise the bar on areas or processes where it might be failing.
    In making essential choices, you need supporting evidence to be able to prevent making an ill-informed choice, and evidence that you had the best source of data, external regulatory or legal advice, for business success as well as SMCR reasonable steps. Bad or incomplete  information can force you into making assumptions or even just guesses and this results in planning poorly or not react is adeqaute time to changes in business or the environment. The wrong choice can hold up a business, attract regulatory censure or enable rivals to get a benefit of your company. If you do not have any robust and accurate information at all you are just arrogantly gambling on the chances of your decisions being right and increase the danger of failure within your company.

    If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on

    0207 097 1434 or email

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    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.
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