Since 2005 Comsure has helped clients deploy comprehensive strategies in response to financial service regulation. Regulatory changes in the financial services industry have come with dizzying speed and complexity, often with massive implications for business models and competitive strategies. We work with clients to: address the impact of new regulatory requirements, and we provide insights […]

Firstly, it’s worth defining what RegTech and FinTech mean.  Two common definitions can be shown as follows:- FinTech’ is the term which describes the intersection between finance and technology. It can refer to technical innovation applied in a traditional financial services context or to innovative financial services that disrupt the existing financial services market. ‘RegTech’ […]

The title of this short missive is derived from a Seychelles News Agency [SNA] press release that has been issued following the recent disclosures about the 1MDb Malaysian sovereign fund scandal. In the SNA press release it is stated; “While reporting that no funds from 1MDb were laundered in Seychelles”, “the FIU confirmed that investigations identified […]

Both the JFSC and FCA have issued their thoughts on OUTSOURCING – in picking through the following I have plucked out some matters that you may like to think about…particularly as the JFSC are silent on the specific matter of ‘cloud’ and other third-party IT services” but Jersey providers should think about this very closely. […]

In this musing I provide updates from FCA/HMT/HMO anti-money laundering and counter-terrorist financing initiatives between APRIL – JUNE 2016 HM TREASURY PUBLISHES FIFTH ANNUAL AML AND CTF SUPERVISION REPORT HM Treasury has published its supervision report for the year to April 2015, which evaluates the effectiveness of the range of approaches taken by supervisors of firms […]

After taking on additional resources (front and back office) and revisiting and improving its working practices Comsure is ready to help both Fund Service Business and Funds themselves in validating and testing their Governance, Risk and Compliance [GRC] programmes.

Thomson Reuters has undertaken its annual survey into the cost of compliance and the challenges firms expect to face in the year ahead (see attached report) and on page 12 (below) I was interested to see the breakdown of a compliance officer’s week……its clear if you don’t support your compliance function there is a risk […]

Following a recent AML training session we looked at the dividing line between ‘recklessness’ and ‘negligence’ as it is important AS It provides the dividing line between the subjective and the objective approaches to mens rea. There are two basic methods of judging mens rea. First of all the court can examine what was going […]