In the UK, the Financial Conduct Authority is asking for more and more 'attestations' that various things have been done from compliance and risk officers and, on 7th March, the Senior Managers and Certification Regime is going to come into force and boost the importance of personal, rather than company, accountability even more. This has given the boffins at Nice Actimize an idea.

The result is a new "Actimize Notifications & Attestations compliance and policy management solution [which] allows compliance professionals to monitor regulatory compliance, to gain better oversight of compliance teams, and to enhance the quality and resolution time of investigations." The product is basically workflow to hold people accountable for having read and understood bulletins and/or having forced others to do so, and therefore to keep the compliance director in the clear if the regulators start asking questions, with an additional repository of rules and regulations thrown in. Regulators have long been levying fines against individuals on both sides of the Pond, so the marketing people at Nice Actimize are hoping that the software will do well in the United States as well.

The software vendor's general manager of case management, speaking from the United States, told Compliance Matters: "The key business challenge we're trying to address is personal and organisational accountability. By 'organisational' we mean the compliance department as an organisation within a bank or a broker. The system does notifications and attestations. Banks can use it to send people their policies and record the fact that they've read them. The really cool thing is that the regulators can see that the compliance department issued new guidance to the workforce and that the the financial institution is following through with that. It shows that people have received and read information about new rules and that they are acting on it."

How does the system show that people are acting on it? The answer, according to the expert, was that it did not actually track the actions that people were taking to comply with the new regulations: "There isn't an automatic mechanism, but it does show that somebody was notified at a point in time, then the story of what they did to comply with it is a narrative that somebody else writes in to the system."

The last feature of this software is called 'effectiveness,' which seems to be something of a misnomer as it relates to people reading rules. The expert went on: "Our analysts tell us that one of the top three things that compliance officers spend their time doing - especially in the anti-money-laundering area - is training people about regulations and teaching them about new ones. The system helps them do it - our case management tool allows people to search for policies and regulations. It's basically for ordinary people - not compliance people - looking up the policies that they're supposed to know about."