Regulatory Handbook Review

Overview

In this very informative project, Aspect Advisory was tasked with reviewing a multi-national corporate bank’s regulatory framework aimed at informing its line managers on the bank’s code of conduct, latest governance trends in anti-money laundering, sanctions and anti-bribery and anti-corruption. The bank had complete compliance handbooks that needed Aspect Advisory’s assurance that they were fully compliant with the latest regulations.

Solution

Aspect Advisory undertook a massive benchmarking exercise where we cross examined contents of the handbooks with up-to-date amendments in laws and regulations as well as researched recent Acts that were passed after the handbooks had been drafted. We also leveraged our vast experience and relationships with comparable financial institutions to benchmark the trending formats and information related to code of conduct, sanctions, anti-bribery and anti-corruption and anti-money laundering.

Result

We produced updated handbooks which incorporated the latest legislation, in particular; Market Abuse Regulation, Foreign corrupt practices act, UK bribery Act, OECD guidelines on anti-bribery, updated the sanctions list based on the list-based sanctions regime, UK sanctions list and addressed issues omitted in the anti-money laundering and counter-terrorist financing by making appropriate reference to the Financial Action Task Force (FATF) and the Bank Secrecy Act. The benchmarking marking exercise allowed us to amend the handbooks by incorporating detailed reviews on Environmental, Social and Governance, as well as the effect of COVID-19 pandemic on compliance

Business Area

Strategy, project management, mergers and acquisition

Skill sets

Research, writing, interpretation of legal texts

Insights

The coronavirus pandemic has increased risks and complicated compliance efforts on a variety of fronts. The major issues that compliance is faced with during the pandemic are as follows:

Budget cuts- One of major issue arising from the pandemic is the stretching of resources, which in most cases, leaves less resources for compliance matters with the company. Compliance departments might face cuts due to the economic downturn resulting from the pandemic, raising concerns about the potential for mistakes or for unethical behaviour to go undetected.
Remote working-travel restrictions complicate the Bank’s ability to monitor and prevent bribery and other misconduct.
PPE-compliance teams are vetting new vendors and suppliers in regard to PPE. This is to ensure that the Covid-19 protocols within the company are compliant with government guidelines and regulations.

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.