𝙒𝙝𝙤 𝙝𝙖𝙨 𝙩𝙤 𝙈𝙤𝙣𝙞𝙩𝙤𝙧?
The obligation to monitor arises under financial service laws & industry Codes, these include:
1. Insurers have an obligation to monitor Distributors & Service Suppliers under the GI Code;
2. All AFS licensee’s have an obligation to monitor representatives (employees & ARs) under financial services laws. This obligation extends to referrers & distributors operating under ASIC instruments;
3. Insurance Brokers have an obligation to monitor AR’s & employees under the Insurance Brokers Code;
4. Claim Managers have an obligation to monitor service suppliers.
5. Agreements include a contractual obligation to monitor & be monitored.
In addition FAR & CPS 230 creates additional monitoring obligations for APRA regulated insurers in respect of Insurance Key Functions (FAR) & Material Service Providers (CPS 230).
𝘿𝙚𝙫𝙚𝙡𝙤𝙥𝙞𝙣𝙜 & 𝙞𝙢𝙥𝙡𝙚𝙢𝙚𝙣𝙩𝙞𝙣𝙜 𝙖 𝙈𝙤𝙣𝙞𝙩𝙤𝙧𝙞𝙣𝙜 & 𝙎𝙪𝙥𝙚𝙧𝙫𝙞𝙨𝙞𝙤𝙣 𝙋𝙧𝙤𝙜𝙧𝙖𝙢
A single, tailored, fit for purpose Monitoring Program can meet all your requirements irrespective of the source – a single program is efficient, risk-based & enables an Enterprise view to manage risk & compliance requirements.
𝙀𝙨𝙨𝙚𝙣𝙩𝙞𝙖𝙡 𝙘𝙤𝙢𝙥𝙤𝙣𝙚𝙣𝙩𝙨 𝙤𝙛 𝙖 𝙈𝙤𝙣𝙞𝙩𝙤𝙧𝙞𝙣𝙜 & 𝙎𝙪𝙥𝙚𝙧𝙫𝙞𝙨𝙞𝙤𝙣 𝙋𝙧𝙤𝙜𝙧𝙖𝙢
1. Due diligence prior to engagement;
2. Agreements that capture obligations of the parties;
3. Onboarding (includes training & education)
4. Alignment to your Risk & Compliance framework
5. Ongoing Training (includes laws & Code, complaints, incidents & breaches)
6. Monitoring, including:
a) file reviews
b) call recording
c) attestations
d) control testing
e) 3 lines of defence activities
f) QA program
g) external events incl regulator activity
7. Supervision, including:
a) new starters without authority;
b) delegated authority
c) Standard Operating Procedures, systems & processes
d) team meetings
e) individual meetings
f) hallway conversations
8. Using people as an ‘early warning system’
9. Incident & breach management
10. Complaint management (IDR & EDR)
11. Data – what is it telling me? (complaints, incidents, Control testing etc)
12. Reporting