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Enterprise Compliance Risk Management: An Essential Toolkit for Banks and Financial Services


Praise for Enterprise Compliance Risk Management

"Enterprise Compliance Risk Management is a unique combination of history, concepts and essential tool kit rolled into one. In a world where many still perceive compliance as a cost function, Ms. Saloni Ramakrishna brings out the much-needed refreshing paradigm shift in both the perception as well as treatment of compliance. Her fluent, unique yet practical handling of this nuanced subject is the hallmark of a thought leader and practitioner, a rare blend. Through her advocacy for a 'positive, preventive and active' approach and a real world context, she brings great value to this young and evolving discipline."
—Dr. Colin Lawrence, Partner, Ernst & Young LLP; former Director, Risk Specialists Division, Financial Services Authority (FSA), UK; former Strategic Risk Advisor to the Deputy Governor, Bank of England

"Ms. Saloni Ramakrishna has long and deep experience in advising financial institutions to enhance and adapt their risk and compliance frameworks to changing external environments. She is truly well-positioned to write about the practitioner's guide on how to design, develop and actually implement logical methodology in the new and evolving compliance risk management landscape. Through this practitioner's guide, she has presented the essential toolkit required for setting in place an effective compliance function. I believe that her work will be a milestone in the literature of banks' operational and compliance risk management, which will chart a course towards the next generation of compliance risk management."
—Tsuyoshi Oyama, Partner, Deloitte Touche Tohmatsu; former Deputy Director-General of the Financial System and Bank Examination Department, Bank of Japan

"Ms. Saloni Ramakrishna, an acknowledged risk and compliance professional, explores the various aspects of compliance and its risk management in the financial services industry in a strikingly lucid manner. This book, Enterprise Compliance Risk Management, with the body of work it encapsulates, is a worthy addition to the literature of the emerging discipline of Compliance Management. A special mention needs to be made for the extra mile she goes to bring out the 'real-world issues' of compliance in the financial services industry in her inimitable style. By addressing the real-life challenges in a meaningful manner and suggesting possible and pragmatic solutions, she has moved compliance and its risk management dialogue beyond financial rhetoric to an actionable business proposition."
—Dr. Ranee Jayamaha, Chairperson, Hatton National Bank PLC; author of The Money Pipeline

"With her extensive and real-world experience as a practitioner in the risk and compliance space, Ms. Saloni Ramakrishna covers the various aspects of the financial services industry's compliance risk management in her simple and straightforward signature style. Her treatment of compliance risk and its definition, 'the risk of impairment of both present and future business, if not compliant and in tune (real or perceived) with environmental expectations,' brings out the nuances of risk in a succinct yet comprehensive manner. The detailing of the sub categories of compliance risk mirrors the layered and complex nature of compliance risk clearly. Special mention needs to be made of the 'Interpretation risk,' which is where most of the real world challenges lie."
—Benjamin Frank, Senior Executive Vice President, HDFC Bank

SALONI P. RAMAKRISHNA has nearly three decades of experience in financial services, both as hands-on professional as well as a solutions architect and contributor to the industry dialogue. She has been invited to share her thoughts and views on industry trends surrounding compliance, risk, customer centricity, performance, and data management in the analytics space by national and international banking and finance forums.

Saloni's ideas have appeared as articles and quotes in newspapers, journals, magazines, and television interviews. She has presented papers at national and international seminars and conferences. Since 2012, she has been a columnist for one of India's leading monthly magazines.

She is currently a Senior Director with Oracle. In her role she frequently interacts with top managers of banks, consulting professionals, financial services bodies, and senior regulators across multiple countries.

Preface xi

Acknowledgments xiii

About the Author xv

Opening Notes xvii

Design and Structure of the Book xix

PART ONE Introduction to Compliance in Financial Services

CHAPTER 1 An Overview of Compliance in Financial Services 5

CHAPTER 2 Compliance in the Twenty-First Century 25

PART TWO The What, Why, and Who of Compliance

CHAPTER 3 What Is “Compliance”? 53

CHAPTER 4 Why Is Compliance Needed? 83

CHAPTER 5 Who Are the Players in the Compliance Universe? 121

PART THREE The How of Compliance

CHAPTER 6 Compliance Framework 159

CHAPTER 7 Operationalizing Compliance 183

PART FOUR The Compliance Risk Dimension

CHAPTER 8 Exploring the Concept of Compliance Risk 213

CHAPTER 9 Compliance Risk Management 239

PART FIVE The Real World of Compliance in Financial Services

CHAPTER 10 Real-Life Issues of Managing Compliance in Financial Services 273

CHAPTER 11 Lessons Not Learned 291

CHAPTER 12 Practical Solutions to Some Important Operational Challenges 315

Closing Notes 325

Index 335