Implementing Compliance Culture across the firm:
Overcoming Challenges and Winning Votes
Ian Lyall, Managing Director, Compliance
J.P.Morgan, London
Riyadh, March 24, 2010
Background
Amalagamation of many firms since the early 90’s
Business and Regional Differences
How do we define Compliance Culture
What are the implications of the wrong sort of culture?
Some differences in culture
Changes in the current environment
The views expressed are personal to the speaker and not necessarily those of J.P.Morgan.
Practical Steps
Tone must be set from the top in words and by example
Requirements must be clearly set out
Code of Conduct
Definition of acceptable and unacceptable practices
Training and Awareness
Clear Compliance policies
Escalation/Challenge must be encouraged
Practical Steps 2
Compliance involvement in all key committees and
processes. Right to say ‘no’
Be imbedded in the business, sit with the business, know
their plans
Be available and let staff know that you are
Explain your decisions
Set your own high standards
Conclusion
Consistency is a challenge
Compliance is owned by Management but we must be
counselling, educating and advising constantly
Training must be comprehensive and policies clear
Compliance must be seen and available and involved in all
aspects of the business