Regulatory handbook review

Overview

Aspect Advisory was engaged by a multi-national corporate bank to review its comprehensive regulatory compliance handbooks. These handbooks were designed to guide line managers on the bank’s code of conduct and key governance topics, including anti-money laundering (AML), sanctions, and anti-bribery and anti-corruption (ABAC). The objective of the engagement was to ensure that the handbooks remained fully compliant with the latest global regulatory standards and reflected current best practices in corporate governance and conduct.

Our Approach

Aspect Advisory conducted a detailed benchmarking and legal alignment exercise. This involved systematically cross-referencing the contents of the existing handbooks with the most recent legislative updates and regulatory amendments. In particular, we reviewed recently enacted laws and regulatory frameworks that were introduced after the original handbooks had been drafted.

Our team also drew on its extensive experience in regulatory compliance and leveraged industry relationships to compare the bank’s approach with evolving standards across peer institutions. This benchmarking extended across key areas such as code of conduct formats, AML obligations, sanctions lists, and anti-bribery/anti-corruption practices, ensuring alignment with international norms and expectations.

Results & Impact

The engagement resulted in fully updated and enhanced compliance handbooks. Key updates included:

Incorporation of the Market Abuse Regulation, Foreign Corrupt Practices Act, UK Bribery Act, and OECD Anti-Bribery Guidelines
Integration of updated sanctions regimes, including the UK Sanctions List and broader list-based sanction requirements
Strengthening of AML and counter-terrorist financing provisions, with explicit references to the Financial Action Task Force (FATF) and the Bank Secrecy Act
Inclusion of emerging themes such as Environmental, Social and Governance (ESG) compliance and the impact of the COVID-19 pandemic on regulatory obligations

The result was a set of robust, user-friendly, and future-focused regulatory handbooks that provided clarity, assurance, and guidance to line managers operating across multiple jurisdictions.

Strategic Themes Addressed

Strengthening regulatory compliance frameworks
Enhancing corporate governance and ethical conduct
Future-proofing compliance against emerging risks

Expertise and Skills Leveraged

Legal and regulatory research
Interpretation and synthesis of complex regulatory texts
Strategic benchmarking and policy drafting

Business Areas Impacted

Corporate Strategy and Governance
Risk and Compliance
Mergers and Acquisitions (due diligence and regulatory assurance)

Insights: Key Learnings & Industry Implications

The COVID-19 pandemic has fundamentally altered the compliance landscape, presenting new risks and operational constraints:

Budget Constraints: Economic pressures have led to resource cuts, including in compliance teams, increasing the risk of oversight or unethical behaviour going undetected.
Remote Monitoring: Travel restrictions and remote work environments complicate oversight, particularly in preventing bribery and misconduct.
Vendor Vetting: Compliance teams now play a critical role in screening new vendors and suppliers—especially regarding PPE procurement—to ensure alignment with evolving health and safety regulations.

These challenges underscore the need for agile and well-resourced compliance frameworks that can adapt quickly in crisis conditions.

Conclusion

Through a thorough and forward-looking review, Aspect Advisory ensured that the bank’s regulatory handbooks are not only compliant with global standards but also responsive to the evolving compliance landscape. The enhancements empower the bank’s line managers with clear, actionable guidance and strengthen the institution’s governance posture in a rapidly changing regulatory environment.