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Compliance programme

Playbook

Draft 0.1.0

Policy refresh after a law change

When the regulatory feed shows a change, find the client's policy clauses it may affect, prepare what would need to change, and send it to the policy owner. Also flags policies that are overdue for review and standard policies the company should have but doesn't. Drafting costs credits and waits for approval; people decide and approve every policy.

ComplyLexara

What starts it

  • On a schedule: check regulatory feed
  • On a schedule: review policy suite
  • In Arakan: law changed
  • When someone asks, e.g. “Does the new CBUAE notice affect our AML policy?”

What the agent does

  • Every week: check for law changes
  • Every month: review and coverage

What stays with a person

  • Deciding whether a law change affects a policy, and recording that decision in Comply
  • Changing or approving a policy's wording
  • Approving, publishing or retiring a policy
  • Asking staff to read and acknowledge a policy

What it never does

  • Change an approved policy, or approve anything
  • Draft a new policy without the compliance lead's confirmation
  • Say a law change doesn't apply; only the policy owner decides that
  • Quote a law from anywhere but Lexara

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