Compliance Health Checks and Mock ARROW
Lysis' Compliance Health Checks and Mock ARROW solution assists firms to prepare for ARROW visits and carry out satisfactory remedial actions afterwards. Specifically we focus on:
- A plan for visit preparation and a rehearsed plan for the visit itself.
- Well prepared attendees who present a clear, common and coordinated view of risks.
- The effective engagement of Executives and NEDs as well as senior managers.
- Presentation of documents and MI that confirm the verbal accounts of risk.
- Clear articulation of risk policy and the demonstration of a strong risk function.
- Demonstration of an appropriate sales culture and effective sales controls.
- Post-visit programmes to remediate issues.
- Clear articulation of the positive impact of these programmes and close communication with the FSA to demonstrate successful remediation.
What happens during an ARROW visit?
- The FSA will review policies and procedures, Business plan, Board and Committee minutes, Audit Reports etc.
- They will then interview approved persons and others to test how policies and procedures work in practice, in order to understand how the firm manages risk, and how it meets its regulatory obligations.
- A letter is sent to the CEO highlighting any issues.
The FSA typically looks for weaknesses in the following areas:
- Strategy, Management and Governance
- Capability of management including NEDs
- Risk management framework
- Capital adequacy
- Compliance with regulation
- BCP
Our approach
Lysis' Compliance Health Check and Mock ARROW consultants have extensive experience having worked at the FSA, on Bank of England and industry-body committees and at a senior level with major UK, US, European and Japanese financial services firms.
We work with our clients to prepare for and remediate after ARROW visits by focussing on:
- Orientation and preparation
- Conducting Mock ARROW workshops and interviews.
- Developing post-ARROW remediating plans and shaping and establishing programmes of work.
- Managing and executing change programmes prompted by ARROW visits.