1. Assess your compliance risks
☐ Identify the key regulatory and compliance risks facing your organisation
☐ Review the industries, countries, customers, and suppliers you work with
☐ Document high-risk activities and areas of exposure
2. Establish compliance policies and procedures
☐ Create documented compliance policies
☐ Define compliance responsibilities across the organisation
☐ Ensure policies are regularly reviewed and updated
☐ Implement software that can automate checks
3. Verify customers and third parties
☐ Verify customer and supplier information
☐ Understand business ownership and control structures
☐ Perform additional checks on higher-risk entities
☐ Screen individuals and businesses against relevant watchlists
☐ Check for politically exposed persons (PEPs)
☐ Review adverse media and reputational risks
☐ Document outcomes
4. Apply enhanced due diligence where required
☐ Identify high-risk customers and business relationships
☐ Conduct deeper investigations into ownership and control
☐ Ensure appropriate approvals are obtained before onboarding
5. Train employees
☐ Provide compliance training to relevant employees
☐ Ensure staff understand their responsibilities
☐ Deliver refresher training regularly
☐ Communicate regulatory updates and emerging risks
6. Maintain records and audit trails
☐ Keep records of decisions and investigations
☐ Ensure information can be retrieved when required
☐ Maintain a clear audit trail of compliance activities
7. Monitor and review
☐ Continuously monitor customers, suppliers, and business relationships
☐ Investigate potential compliance concerns promptly
8. Report and escalate issues
☐ Establish clear reporting procedures
☐ Escalate high-risk matters appropriately
☐ Investigate compliance breaches and incidents
☐ Document actions taken and lessons learned
9. Continuously improve your programme
☐ Review compliance controls regularly
☐ Update policies in response to regulatory changes
☐ Implement improvements identified through audits and reviews
Final compliance review
Before considering your compliance programme complete, ask:
☐ Do we understand our compliance risks?
☐ Are our policies documented and up to date?
☐ Do we conduct appropriate due diligence?
☐ Can we demonstrate compliance through records and audit trails?
☐ Are employees trained and aware of their responsibilities?
☐ Do we monitor for changes in risk?
☐ Do we review and improve our programme regularly?
☐ Are we confident in the people and organisations we do business with?