, ,

Compliance Risk: Definition, Assessment, the CMS and How Internal Audit Tests It

Compliance risk is the risk of legal or regulatory sanctions, financial loss or reputational damage that an organisation suffers when it fails to comply with laws, regulations, rules, codes of conduct and standards of good practice that apply to its activities. It is the risk category with the widest span (every law that touches the business), the one most often confused with the function that manages it, and the one where the gap between a program that exists on paper and a program that works is hardest to see from the outside. This is the Risk Library reference on the subject: what compliance risk is and how it differs from compliance, conduct risk and legal risk; where it comes from; how it is assessed and measured; what a compliance management system contains and what regulators expect of it; the regulatory change and complaint processes that feed it; how compliance monitoring, compliance testing and internal audit divide the work; where enforcement attention sits in 2026; and a worked compliance risk management audit at an illustrative nine-billion-dollar bank.

It absorbs the former short explainer on compliance versus compliance risk as its second section, and it is the reference behind three engagement guides: the compliance risk assessment method, the ethics and compliance program audit and the BSA/AML independent testing program.

In this guide

What compliance risk is

The Basel Committee’s 2005 paper on compliance and the compliance function in banks gave the definition most frameworks still use: the risk of legal or regulatory sanctions, material financial loss, or loss to reputation a bank may suffer as a result of its failure to comply with laws, regulations, rules, related self-regulatory organisation standards, and codes of conduct applicable to its banking activities. The Office of the Comptroller of the Currency’s version is shorter and makes the same point: the risk to current or projected financial condition and resilience arising from violations of laws, rules or regulations, or from non-conformance with prescribed practices, internal policies and procedures, or ethical standards. Three features of the definitions matter for anyone measuring or auditing the risk.

First, the consequence is defined broadly: sanctions, financial loss and reputational damage, which means a compliance failure with no fine can still be a material compliance event. Second, the scope includes codes of conduct and internal policies, not only law, which is why conduct risk and compliance risk overlap and why an organisation’s own standards become compliance obligations once adopted. Third, the risk attaches to activities, so it is inherent in what the organisation does and cannot be eliminated by the compliance function, only managed by the business with the function’s help. The risk taxonomy guide shows where compliance risk sits among the other categories, and the OCC risk categories guide how the OCC places it alongside strategic, reputation and operational risk.

Compliance versus compliance risk, conduct risk and legal risk

Four terms are run together in most organisations, and separating them is the first thing an auditor does when scoping any engagement in this area.

TermWhat it meansExampleWhy the distinction matters
ComplianceThe state of conforming to the applicable obligations; also the function that supports conformance“The bank is in compliance with the flood insurance rules”; “compliance reviewed the disclosure”Compliance is an outcome or a function; it is not the risk. Auditing “compliance” without saying which obligations is unscopeable
Compliance riskThe risk that the organisation fails to conform and suffers sanctions, loss or reputational damageThe risk that a new deposit product’s fee disclosures violate Truth in SavingsThe thing that is assessed, measured, limited and reported; the business owns it
Conduct riskThe risk that the organisation’s or its people’s behaviour produces poor outcomes for customers, markets or the organisation, whether or not a rule is brokenSelling a suitable product with pressure tactics; a sales incentive that drives unneeded accountsConduct failures often precede rule changes; the UK framework treats conduct as its own category. The conduct risk guide covers it
Legal riskThe risk of loss from unenforceable contracts, litigation, adverse judgments or defective legal documentationA guarantee that is unenforceable because it was signed without authorityManaged by the legal function; overlaps with compliance where litigation follows a compliance failure
Regulatory riskThe risk that regulation changes in ways that affect the business model or its costA rule capping a fee the business depends onA strategic risk about the future rulebook, not a failure to comply with the current one

The distinction that causes the most trouble in practice is the first: an organisation with a compliance function is not therefore managing compliance risk, any more than an organisation with an accounting department is therefore managing financial reporting risk. The function assesses, advises, monitors and reports; the business lines own the risk, embed the controls and are accountable for the outcomes. An audit that finds a well-staffed compliance function and a business that treats compliance as someone else’s job has found the most common compliance finding there is.

Where compliance risk comes from

Compliance risk is inherent in activities, and the inventory of obligations is the starting point of any assessment. The table groups the main sources for a financial institution, with the obligations that generate most of the risk in each and the business activities that carry it; a non-financial organisation substitutes its own regulatory map (employment, environmental, product safety, data protection, anti-corruption, trade sanctions, sector licensing).

SourceRepresentative obligations (US unless noted)Activities that carry the riskTypical failure
Consumer protectionTruth in Lending, Truth in Savings, Equal Credit Opportunity, Fair Housing, Fair Credit Reporting, Electronic Fund Transfer, Real Estate Settlement Procedures, UDAAP, Servicemembers Civil Relief, Flood Disaster ProtectionDeposit and lending products, servicing, collections, marketingDisclosures that do not match the product as built; fee practices; fair lending disparities
Financial crimeBank Secrecy Act and AML program rules, OFAC sanctions, anti-bribery (FCPA, UK Bribery Act), fraud statutesOnboarding, payments, correspondent banking, trade finance, third-party agentsAlert backlogs; weak customer due diligence; sanctions screening gaps; see the BSA/AML testing guide
Privacy and dataGramm-Leach-Bliley, state privacy laws, GDPR and UK GDPR for EU and UK data, breach notification rulesEvery customer data flow; marketing; vendorsData shared beyond the notice; breach notifications late
Prudential and safety and soundnessCapital and liquidity rules, lending limits, affiliate transaction rules (Regulation W), insider lending (Regulation O), call reportingTreasury, lending, finance, regulatory reportingReporting errors; limit breaches; affiliate transactions undocumented
Securities and marketsSecurities Exchange Act rules for broker-dealers, investment adviser rules, market conduct rules, Volcker RuleCapital markets, wealth management, trustSuitability; best execution; proprietary trading boundaries
Employment and workplaceWage and hour, anti-discrimination, health and safety, whistleblower protectionHuman resources, every managerMisclassification; retaliation
Conduct and ethicsCodes of conduct, gifts and entertainment, conflicts of interest, insider trading policiesEveryone; sales incentives; front officeIncentive-driven mis-selling; undisclosed conflicts
Governance obligationsSarbanes-Oxley certifications, listing rules, board composition and committee requirementsFinance, legal, the boardCertification processes that are ceremonial

Two sources deserve a note because they are growing. Third parties carry the organisation’s compliance obligations into places the organisation does not see: a fintech partner originating accounts, a collection agency, a marketing vendor; the third-party risk management guide and the Third-Party Topical Requirement address the governance, and compliance risk assessments should include the third-party channel explicitly. And artificial intelligence in customer-facing processes (credit decisions, marketing, servicing chatbots) creates compliance exposure under existing fair lending, UDAAP and privacy rules before any AI-specific rule applies; the auditing AI governance guide covers the control framework.

Assessing compliance risk: the inherent and residual map

A compliance risk assessment is a matrix: obligations (or regulatory areas) down the side, business units or products across the top, and in each cell an inherent risk rating, a control effectiveness rating and the residual risk that results. The compliance risk assessment guide works through the method step by step; the summary here is what the assessment must contain to be credible and the ways it goes wrong.

ElementWhat good looks likeWhat weak looks likeAudit test
Obligation inventoryA maintained inventory of applicable laws, rules and standards mapped to products, processes and owners, with a defined process for additionsA list copied from a vendor library with no mapping to the businessTrace a sample of obligations to owners and controls; check that recent rule changes appear
Inherent risk scoringScored on defined factors: volume, complexity, change, customer harm potential, enforcement history, penaltiesEverything scored medium; scores unchanged for yearsTest the scoring rationale for the ten highest and ten lowest cells
Control assessmentControls identified per obligation; design and operating effectiveness supported by monitoring and testing resultsControls rated effective because they existTrace control ratings to monitoring and testing evidence
Residual risk and appetiteResidual risk compared to a stated appetite; high residual cells have action plans with owners and datesResidual risk reported with no consequenceConfirm action plans exist for high residual cells and are tracked
Refresh cadenceAnnual refresh plus triggers: new product, acquisition, rule change, enforcement action, significant complaint trendAnnual only; new products launched between refreshes unassessedCheck that products launched in the year were assessed before launch
UseThe assessment drives the monitoring plan, the testing plan, training priorities and the audit planThe assessment is produced for the board and filedCompare the monitoring and testing plans to the assessment’s high-risk cells

The assessment’s purpose is allocation: it decides where compliance monitoring and testing, training and audit hours go. An assessment that does not change any of those allocations is a report, not a risk assessment, and an internal auditor reads the monitoring plan against the assessment to see whether the function believes its own numbers.

The compliance management system and what regulators expect

US regulators describe the architecture they expect as a compliance management system (CMS), and the elements are consistent across the FFIEC examination manuals, the CFPB’s supervision manual and the OCC’s guidance: board and management oversight; a compliance program consisting of policies and procedures, training, monitoring and corrective action; a consumer complaint response process; and an independent compliance audit. For the largest banks the OCC’s heightened standards (for institutions with average total assets of 50 billion dollars or more) and the Federal Reserve’s 2008 guidance on compliance risk management programs at large banking organisations add expectations of firm-wide compliance risk management, an independent compliance function with a reporting line to the board or a board committee, and a compliance risk assessment that spans the enterprise. Outside banking the architecture is the same under different names: the US Sentencing Guidelines’ seven elements of an effective compliance and ethics program, the Department of Justice’s evaluation of corporate compliance programs (most recently updated in September 2024, with new attention to the use of data, to AI risk and to whistleblower treatment), the UK FCA’s systems and controls sourcebook, and ISO 37301 on compliance management systems.

ElementWhat regulators look forEvidence an auditor asks forFrequent gap
Board and management oversightBoard approves the program and appetite; receives risk assessment, monitoring and testing results, complaint trends, regulatory change; a qualified chief compliance officer with independence and statureCharter, board and committee minutes, CCO reporting line and appraisal, resourcing analysisBoard sees a status dashboard but not the risk assessment or testing results; CCO reports to the general counsel or the business
Policies and proceduresCurrent, mapped to obligations, approved, communicated, with exceptions governedPolicy inventory with review dates and owners; mapping to the obligation inventoryPolicies that describe the rule rather than the bank’s process; stale review dates
TrainingRole-based, risk-based, tracked, with completion and comprehension measuredTraining plan tied to the risk assessment; completion records; test resultsAnnual generic modules for everyone; completion tracked, comprehension not
MonitoringFirst-line and compliance-function monitoring of transactions, disclosures and processes against the obligations, risk-based in frequency and depthMonitoring plan, results, issues raisedMonitoring that confirms a checklist was completed rather than that the outcome was compliant
TestingIndependent, sample-based compliance testing by the compliance function (distinct from monitoring and from internal audit)Testing plan tied to the risk assessment; workpapers; findings; sample sizesTesting of low-risk areas because they are easy; no retesting of remediated issues
Issue management and corrective actionIssues from any source tracked to root cause and remediation with owners, dates and validation; self-identification creditedIssue log, root cause analyses, validation evidenceIssues closed on management assertion; repeat issues not flagged
Complaint responseComplaints captured from every channel, categorised, root-caused, trended and escalatedComplaint data, categorisation rules, trend reportsComplaints handled but not analysed
Compliance auditInternal audit coverage of the CMS and of high-risk obligations, independent of complianceAudit universe, plan, reportsAudit relies on compliance testing without testing it

Regulatory change management

The obligation inventory decays from the day it is written, and regulatory change management is the process that keeps it current: identifying new and amended obligations, assessing applicability and impact, assigning owners, implementing changes to policies, systems, disclosures and training, and confirming the change landed before the effective date. The process has a recognisable set of controls and a recognisable set of failures.

StepControlEvidenceFailure that recurs
Horizon scanningDefined sources (agency releases, Federal Register, state regulators, trade bodies, vendor feeds) reviewed on a schedule with a logChange log with source, date identified and date of effectSources limited to one vendor feed; state rules missed
Applicability and impact assessmentEach change assessed for applicability, affected products and processes, and effort, by a named owner, within a set timeAssessment record per changeChanges marked “not applicable” without rationale
ImplementationProject or task tracking with owners and dates against the effective date; system, policy, disclosure and training changes itemisedProject records, change tickets, policy versionsImplementation complete on the effective date in policy but not in the system
Pre-effective validationCompliance testing or monitoring confirms the change operates before or shortly after the effective dateValidation workpapersNo validation; the first evidence of failure is a complaint or an exam finding
Inventory updateObligation inventory and risk assessment updated for the changeInventory version historyInventory updated annually, months after the change

An audit of regulatory change management is a tracing exercise: select ten changes from the year with effective dates in the period, and follow each from identification through assessment, implementation and validation to the inventory, measuring elapsed time at each step against the effective date. The findings write themselves when a change identified in March took effect in July and was implemented in the system in October.

Complaints: the data the program runs on

Complaints are the richest data source a compliance program has, because customers report the failures that monitoring did not catch, and regulators treat complaint handling and complaint analytics as a core CMS element. The program needs capture from every channel (branches, call centres, digital, social media, regulators, the CFPB portal where applicable, legal), consistent categorisation by product and issue, root cause analysis for recurring categories, trend reporting with thresholds, and escalation of complaints that allege discrimination, UDAAP, or harm to vulnerable customers. The audit tests are completeness (are complaints from every channel reaching the system; sample call recordings and social media for unlogged complaints), categorisation accuracy (re-categorise a sample), timeliness (response times against policy and regulation), root cause (are the top categories traced to a cause and an action), and use (does the complaint trend change the risk assessment and the monitoring plan). A function that reports complaint volumes without root causes has a reporting system, not a compliance control.

Monitoring, testing and audit: who does what

Compliance assurance has three layers, and confusion between them produces both gaps and duplication. The internal audit versus compliance guide covers the relationship in full; the table summarises the division of labour and the reliance rules.

LayerWhoWhatIndependenceHow internal audit uses it
MonitoringFirst line (business quality control) and the compliance functionOngoing checks of transactions, disclosures and processes as they occur; high frequency, broad coverageFirst-line monitoring is not independent; compliance monitoring is independent of the business but part of the programEvidence of control operation; tested rather than relied on
Compliance testingThe compliance function’s testing teamPeriodic, sample-based, independent tests of compliance with specific obligations, planned from the risk assessmentIndependent of the business and of monitoring; part of the second lineReliance possible after testing the testing: methodology, sample sizes, competence, independence, and reperformance of a sample
Internal auditThird lineAudits the CMS as a system and audits high-risk obligations directly; opines to the audit committeeIndependent of bothOwns the opinion on the program; coordinates coverage with testing to avoid gaps and duplication

The reliance decision follows the same logic as reliance on credit risk review or on model validation, covered in the auditing ERM guide: internal audit may reduce direct testing where the compliance testing function is independent, competent and its work has been tested, and must document that conclusion annually. It cannot rely where testing reports to the business, where the testing plan omits the high-risk cells, or where sample sizes cannot support the conclusions drawn.

Metrics and reporting

Compliance risk reporting to the board and the risk committee should show the level and trend of the risk, not the activity of the function. The distinction is the difference between “training completion 98 per cent” and “two of the twelve high-residual-risk cells have overdue action plans”. The key risk indicator program guide and the KRI tables give the general method; the table lists the indicators a compliance report should carry.

IndicatorWhat it showsThreshold logicWeak substitute
High residual risk cells with overdue actionsWhether the assessment is driving remediationAny overdue action is reportable; trend mattersCount of policies reviewed
Issues by source (self-identified, monitoring, testing, audit, examiner, complaint) and ageWhether the program finds its own problems before regulators doExaminer-identified share rising is a program failureCount of open issues
Repeat issuesWhether remediation holdsAny repeat is reportableIssues closed
Complaints per thousand accounts by product, with allegation categories (discrimination, UDAAP, fees)Customer-reported failuresThresholds by product; spikes investigatedTotal complaints
Regulatory changes past effective date without validated implementationChange management performanceZero is the targetChanges logged
Monitoring and testing plan completion against the risk-based plan, with exceptions foundWhether the assurance layers are operatingDeferred tests of high-risk cells reportableTests completed
Training: comprehension and role coverage for high-risk rolesWhether people know the rules that apply to themComprehension below threshold in a high-risk role is reportableCompletion rate
Regulatory matters: MRAs, consent orders, fines, exam ratings, with statusThe external verdictAny open matter reportable with milestones; see the MRA lifecycle guideNarrative only

Where enforcement attention sits in 2026

A reference guide should say where the risk is being enforced at the time of writing, because an audit plan that ignores the enforcement environment allocates hours to the wrong obligations. Four observations hold in 2026. Federal consumer financial enforcement in the United States changed shape in 2025: the Consumer Financial Protection Bureau’s staffing, guidance and enforcement footprint were cut back sharply, several actions and interpretive rules were withdrawn, and the prudential regulators and state attorneys general became the more active consumer enforcers; a program that calibrated its risk assessment to CFPB activity alone has mis-scored the risk, because the underlying statutes did not change and state enforcement and private litigation did not slow. Financial crime enforcement did not pause: AML program failures, sanctions violations and the fintech partnership model (banks providing accounts and payments for third-party programs) produced consent orders through 2024 and 2025, and third-party and partner oversight is the obligation most often cited. Fair lending remains a live exposure through the Equal Credit Opportunity Act and the Fair Housing Act regardless of agency priorities, and the use of models and AI in credit decisions has become a standard examination question. And the Department of Justice’s September 2024 update to its compliance program evaluation added questions about whether companies use data analytics in compliance, manage the risks of AI and emerging technology, and protect whistleblowers, which corporate compliance programs outside financial services now have to answer.

How internal audit tests compliance risk management

A compliance risk management audit tests the system, not the obligations one by one; obligation-level audits (fair lending, BSA/AML, flood, servicing) are separate engagements in the universe, as the bank audit universe example shows. The program has nine areas, mapped to the CMS elements, and the ethics and compliance program audit guide gives the non-financial version.

AreaKey testsEvidenceTypical finding
GovernanceCCO reporting line, independence and stature; board reporting content; resourcing against the risk assessmentCharter, org chart, minutes, reportsCCO reports to the general counsel; board receives activity metrics only
Risk assessmentInventory completeness; scoring rationale; refresh triggers; use in planningInventory, assessment, monitoring and testing plansAssessment not used to plan monitoring or testing
Policies and trainingMapping to obligations; currency; role-based training tied to riskPolicy inventory, training plan and resultsGeneric training; policies restate the rule
MonitoringDesign against the obligation; results; issues raised; first-line versus compliance monitoringMonitoring plan and resultsChecklist monitoring that cannot detect outcome failures
TestingPlan against the risk assessment; methodology; sample sizes; reperform a sample of testsTesting plan, workpapersTesting of convenient areas; samples too small
Regulatory changeTrace ten changes end to end against effective datesChange log, assessments, implementation recordsImplementation after the effective date; no validation
ComplaintsCompleteness across channels; categorisation; root cause; useComplaint data, call samples, trend reportsUnlogged complaints in call recordings; no root cause
Issue managementRoot cause; remediation validation; repeat issues; examiner findings trackedIssue log, validation evidenceIssues closed on assertion; repeats
Reliance and coordinationInternal audit’s reliance on compliance testing documented and supportedReliance memo, test of testingReliance without testing the testing

The three most informative procedures are reperformance of a sample of compliance tests (does the testing team’s conclusion hold when the auditor re-does the test), the end-to-end trace of regulatory changes, and the complaint completeness test using call recordings and social media, because each tests an outcome the program claims rather than a document the program produced. The audit work program guide covers documentation and the what regulators expect guide how an examiner will read the function’s coverage.

Worked example: Lakeshore Bancorp’s FY27 compliance audit

Lakeshore Bancorp is the illustrative nine-billion-dollar public regional bank used across this site, with a twenty-two person internal audit function and a compliance department of about forty. Its FY27 plan scheduled a 520-hour audit of the compliance risk management program, the first system-level audit since FY24; obligation-level audits (BSA/AML, fair lending, mortgage servicing) ran on their own cycles. The engagement followed the program above.

AreaWhat the audit foundRating
GovernanceThe chief compliance officer reported to the general counsel with a dotted line to the board risk committee; the committee received a quarterly dashboard of training completion, policy reviews and complaint volumes, and had not seen the compliance risk assessment since FY25High: independence and reporting
Risk assessmentInventory of 214 obligations mapped to products and owners, refreshed annually; 38 of 61 high-inherent-risk cells rated “effective controls” with no monitoring or testing result in the prior twelve months to support the rating; the FY27 monitoring plan covered 19 of the 61High: control ratings unsupported; plan not driven by the assessment
Regulatory changeTen changes traced: median 41 days from identification to assessment; three changes implemented in systems after their effective dates (by 23, 48 and 95 days); none validated before the effective date; one state servicing rule missed because the scanning sources covered federal releases onlyHigh
ComplaintsA sample of 120 call recordings produced 9 complaints meeting the policy definition that were not logged (7.5 per cent); social media not monitored; top three categories trended but not root-causedMedium
TestingTwenty tests reperformed: eighteen conclusions supported; two fee-disclosure tests used samples of five accounts and concluded “no exceptions” on populations above 20,000Medium: sample sizes
Issue managementOf 44 issues closed in the year, 31 closed on management’s assertion without validation; four were repeats of FY25 issuesMedium
TrainingCompletion 97 per cent; comprehension measured only on the ethics module; mortgage originators had no role-based fair lending training beyond the general moduleLow
RelianceInternal audit’s FY26 fair lending audit had relied on compliance testing results without testing the testing; the reliance memo was written after the factMedium (self-identified)

The engagement was rated Needs Improvement with three High findings. Management’s actions: a direct reporting line from the chief compliance officer to the board risk committee, effective at the next board meeting, with the risk assessment and testing results on the committee’s standing agenda; a re-rating of the 61 high-inherent-risk cells against actual monitoring and testing evidence, with the FY27 testing plan reset to cover every high-residual cell; a regulatory change procedure with a ten-day assessment standard, state-regulator sources added to the scan, and pre-effective-date validation; a complaint capture refresh with speech analytics on call recordings; and a sample size standard for compliance testing. Internal audit’s own reliance practice was corrected with a documented test-of-testing each year before any reliance. The findings were validated under the issue validation standard, with the regulatory change finding validated by tracing the next ten changes.

Frequently asked questions

What is the difference between compliance and compliance risk?

Compliance is the state of conforming to the obligations that apply to the organisation, and by extension the function that supports conformance. Compliance risk is the risk that the organisation fails to conform and suffers sanctions, loss or reputational damage as a result. The business owns the risk; the compliance function assesses, advises, monitors, tests and reports. An organisation can have a compliance function and still manage compliance risk badly, which is the most common finding in this area.

What is a compliance management system?

The architecture US regulators expect for managing compliance risk: board and management oversight, a compliance program (policies and procedures, training, monitoring and corrective action), a consumer complaint response process, and an independent compliance audit. The FFIEC examination manuals and the CFPB supervision manual describe it in those terms; the OCC’s heightened standards and the Federal Reserve’s guidance on compliance risk management programs add enterprise-wide expectations for large banks. Outside banking the equivalent is the US Sentencing Guidelines’ seven elements and the Department of Justice’s compliance program evaluation.

How is compliance risk measured?

Through the compliance risk assessment: inherent risk scored on defined factors for each obligation and business unit, control effectiveness supported by monitoring and testing evidence, residual risk compared to appetite, and action plans for high residual cells. The measure is only as good as the evidence behind the control ratings, and the assessment is only useful if it drives the allocation of monitoring, testing, training and audit hours. The compliance risk assessment guide works through the method.

What is the difference between compliance monitoring, compliance testing and internal audit?

Monitoring is ongoing checking of transactions and processes as they occur, by the first line and the compliance function. Testing is periodic, sample-based, independent testing of specific obligations by the compliance function’s testing team, planned from the risk assessment. Internal audit is the third line, which audits the compliance management system as a whole and high-risk obligations directly, and may rely on compliance testing only after testing it. The internal audit versus compliance guide covers the relationship.

Does conduct risk belong under compliance risk?

They overlap and are managed together in most organisations, but they are distinct: compliance risk is about failing to meet obligations; conduct risk is about behaviour that produces poor outcomes for customers or markets whether or not a rule is broken, and it often precedes the rule. UK regulators treat conduct as its own category; US frameworks tend to capture it through UDAAP and codes of conduct. The conduct risk guide treats it on its own terms.

How should a compliance program respond to the changes in US enforcement since 2025?

By recognising that the obligations did not change when the enforcer’s posture did. The statutes behind consumer protection, fair lending, financial crime and privacy remain in force, state attorneys general and prudential regulators are active, private litigation continues, and administrations change. A risk assessment that lowered inherent risk scores because one agency stepped back has mis-scored the risk; the defensible response is to hold the scores to the law and the harm potential, and to track the enforcement environment as context rather than as the measure.

What should the board see about compliance risk?

The level and trend of the risk rather than the activity of the function: the risk assessment and its high residual cells with action status; issues by source and age, with the share found by regulators rather than by the program; repeat issues; complaint rates and allegation categories by product; regulatory changes past their effective date without validated implementation; monitoring and testing completion against the risk-based plan; and the status of every regulatory matter. Training completion and policies reviewed are inputs, not outcomes.

How often should internal audit cover the compliance management system?

As a system, every two to three years with annual coverage of the highest-risk obligations and continuous monitoring of the indicators above in between; annually for large banks under heightened standards, where examiners expect audit’s coverage of the compliance program to be explicit. The bank audit universe example shows how the system-level audit and the obligation-level audits are sequenced.

Free PDF · 15 one-page cheat sheets

The Internal Audit Desk Reference, free by email.

GIAS 2024 on one page, the sample-size tables, the risk and control matrix, the five-C finding, the SOX deficiency ladder, the CIA exam at a glance, and nine more. Printable. Written by working auditors.

Free. Confirm your address once; the PDF link follows. Unsubscribe anytime.

Cover of The Internal Audit Desk Reference: fifteen one-page cheat sheets and templates (PDF)
Cover of The Internal Audit Desk Reference: fifteen one-page cheat sheets and templates (PDF)

Free PDF

The desk reference: 15 cheat sheets, one page each.

GIAS map, sample sizes, the RCM, the five-C finding, SOX deficiency ladder, CIA at a glance. Free, printable.

Confirm once; the PDF link follows. Unsubscribe anytime.

Comments

Leave a Reply