Health Check Compliance Reviews

Are you in compliance with CySEC's requirements? 

In an environment with increasing regulatory focus, it is critical for Cyprus Investment Firms ('CIFs') to have in place policies, processes and procedures that are compliant with and satisfy the requirements of the Regulator in an effective and efficient manner. To this effect, many market participants are nowadays performing focused 'health check' compliance reviews of their operations to identify areas where changes or adjustments need to be implemented to comply with CySEC Laws, Directives and recent Circulars, and to ensure the appropriate treatment of their customers and other associates, thus avoiding issues that may result in business, reputational and/or financial detriment.

Such Compliance Reviews can address in a very focused and customised manner a number of areas, including, but not limited to:

Illustrative Examples 

Organisation structure and Governance

  • Organisational structure
  • Involvement of the Board
  • Compliance with the provisions for "Significant CIFs", if relevant
  • Roles and responsibilities of management/employees/Committees
  • Compliance Monitoring procedures
  • Internal Operations Manual 

Information provided to clients

  • Marketing material and communications
  • Trading bonus schemes, if relevant
  • MiFID information provided to clients
  • Calls recording and monitoring
  • Complaints handling procedures 

Servicing clients

  • Providing services to clients, in line with the CIF's license
  • Order Execution and Conflicts of Interest policies
  • Services provided to clients in other EU and third countries (cross-border or through a branch)
  • Funds deposits and withdrawals
  • CIF website 

Reporting requirements

  • Communication with CySEC and other regulators, if relevant
  • Compliance with reporting obligations
  • Completeness and accuracy of the XML files submitted to CySEC 

Remuneration Practices

  • Remuneration policy
  • Procedures for paying variable remuneration to employees 

Client On-boarding

  • "Know Your Customer" ("KYC") procedures and documentation obtained during on-boarding
  • AML policy and procedures
  • Appropriateness and Suitability Tests
  • KYC/AML reviews 

How PwC can help you

PwC Cyprus has a dedicated team of local experts with experience in Compliance Reviews, who work closely with our global  network of specialists to provide you with tailored advice and support on how to comply with CySEC requirements in an efficient and effective manner. Services in relation to Compliance Reviews include:

  • Gap Analysis and Action Plan - Performance of a gap analysis to identify the 'gaps' between the current processes followed by the Company vs. CySEC's relevant requirements and development of an Action Plan describing the actions the Company will need to take to bridge any resulting 'gaps'.
  • Implementation of Action Plan - Assisting in the implementation of enhanced and compliant processes and procedures including the preparation/review of relevant policies and procedures, according to the Action Plan, as well as providing related project management support.
  • Trainings and tailored workshops - Provide training and tailored workshops for management and employees on matters related to the Compliance Review. 

Contact us

George Lambrou

Partner, Advisory | In charge of Internal Audit, PwC Cyprus

Tel: +357-22555728

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