Advisory to banks and financial intermediaries

Privacy (GDPR)

• Assessment, Gap analysis, and Action plan in the implementation/revision of the privacy model
• DPO outsourcing/support
• Advisory (e.g. processing register management; DPIA, Privacy by design/default; data breach assessment; exercise of data subject rights, task assignment)

Liability 231/01

• Regulatory monitoring (e.g. evolution of the provisions on predicate crimes 231 and thematic jurisprudence)
• Assessment, Gap analysis, and Action plan in the implementation/revision of the Code of Ethics, MOG, 231 Supervisory Board regulation
• Methodological setting of controls
• Annual activity plan and support for 231 Supervisory Board checks
• Positions in 231 Bodies
• Classroom training courses and specialized conferences
• Regulatory check-ups

Internal reporting

• Gap analysis, whistleblowing policy
• Assistance in internal report verification activities
• Assistance in managing relations with Corporate Bodies

Anti-money Laundering

• Monitoring of suspicious transactions (Segnalazione di Operazione Sospetta – SOS) and client ratings development (Cosmos)
• Check for correct data supply to the “Archivio Unico Informatico” – Unique Digital Archive (Diagnostic)
• Yearly AML risk self-assessment data processing: inherent risk, safeguard vulnerability, residual risk

Whistleblowing

• Management of internal reporting processes across regulatory frameworks (e.g. anonymous reporting)
• Encryption and traceability of data flow
• Structured workflow for rapid and immediate information accessibility by reporters and recipients. Document repository services.

Internal Controls

• “Insider” register, RIL and SOS (Market abuse)
• Register of complaints, activities and checks on control functions, conflicts of interest, incentives, insider lists, outsourcing
• Register of outsourced functions

Regulatory Alerts

Monitoring and mapping of key regulatory updates in the banking and financial sector (Daily Alert)

Advisory, Impact Analysis and Internal Processes Evaluation

• Impact analysis on intermediary’s operations post regulatory changes and good practices
• Evaluation of the adequacy and effectiveness of the internal control system in risk mitigation
• Assessment of organizational structures, including outsourcing of key operational functions
• Assistance in updating internal regulations (e.g. Policies, Regulations, Procedures, Manuals)

Training

• Company representatives and corporate control functions
• Banking, financial and payment services
• Investment services and insurance distribution
• Money Laundering Risk Prevention
• Legislative Decree 231/01, Whistleblowing, ICT Risk and GDPR

Outsourcing

• Outsourcing of control functions (Internal Audit, Compliance, ICT Risk, Risk Management, AML Manager), in compliance with supervisory requirements
• Internal regulation and methodology of outsourced control functions
• Activity plan and implementation of controls, including upon request of the Supervisory Authorities
• Activity plan and implementation of controls, including upon request of the Supervisory Authorities

Co-sourcing

• Sharing of risk assessment methodologies and internal controls
• Collaboration in the preparation of the activity plan, assistance with checks and follow-up
• Support in the preparation of reports and communication to corporate bodies and Supervisory Authorities
• Support on specific AML/CTF issues (e.g. risk self-assessment and AUI checks)