Corporate Compliance, Risk, and Governance Action Plan
This report presents findings from an internal audit of WB, a financial services firm, and proposes a structured action plan to address identified compliance failures. Key concerns include high-risk investment products sold to elderly clients without board approval, a weak compliance culture, inadequate record-keeping, insufficient employee training, and the absence of a formal compliance manual. The report outlines recommended corrective measures across governance, risk, and compliance (GRC) domains, including board and senior management accountability, establishment of a compliance manual and program, cultural reform, targeted training, and implementation of a Compliance Management System (CMS). Both short-term and long-term measures are addressed.
- Overview of Key Audit Findings: Internal audit reveals compliance failures and cultural weaknesses
- Board and Senior Management Compliance Responsibilities: Board and executives must own and enforce compliance policy
- Compliance Manual and Program: Eight-element compliance manual framework for WB
- Building a Compliance Culture: Leadership-led cultural reform to embed ethical conduct
- Compliance Training: Targeted training for all staff on regulatory requirements
- Compliance Management System: CMS with oversight, program, and audit components
- Conclusion: Board-led corrective action essential for sustained compliance
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What makes this paper effective
- Systematically moves from problem diagnosis to solution, giving the report a clear, board-friendly structure that mirrors real-world executive reporting conventions.
- Grounds each recommendation in named sources (KPMG, FDIC, Compliance 360) rather than unsupported assertions, lending credibility to the action plan.
- Distinguishes between short-term and long-term actions, demonstrating awareness of implementation sequencing and organizational change management.
- Ties culture, training, and governance together as interdependent, reinforcing the core argument that isolated fixes are insufficient without systemic reform.
Key academic technique demonstrated
The paper demonstrates applied policy analysis: it translates abstract GRC frameworks into concrete, organization-specific recommendations. By connecting identified weaknesses (e.g., absence of a compliance manual, lack of board oversight) directly to proposed remedies (e.g., CMS, written compliance policy), it shows how academic frameworks are operationalized in a professional context — a technique central to business and governance writing.
Structure breakdown
The report opens with an audit findings summary, then moves through five thematic action areas — board accountability, compliance manual, culture, training, and the CMS — each addressed in its own section. A conclusion synthesizes the recommendations and reaffirms board responsibility. This structure follows the conventions of a professional advisory report directed at organizational leadership.
Overview of Key Audit Findings
This report presents to the board of WB a brief overview of the key findings from the review undertaken, elucidating the concerns identified in an internal audit. The report then offers a clear explanation of why continuation of existing practices — and the absence of corrective measures — will be risky and detrimental to WB. It also includes an initial plan of action to address the weaknesses identified, in both the short term and long term, along with an explanation of the necessity of the proposed corrective actions, some of which are pre-emptive.
One of the key issues identified in the internal audit was that a number of high-risk investment products, with a suggested minimum investment term of over ten years, were sold to consumers aged in their 80s — a high-risk consumer category. Moreover, such proposals were not communicated to the board of the company before the deals were finalized. Secondly, there is evidence of a poor sales and compliance culture. The investigation revealed a lack of due diligence in the internal audit and in the record-keeping of customer accounts. It was found that there had been minimal oversight of sales activities in relation to high-risk products, either by management within that area or by the Compliance and Assurance team.
WB currently lacks a well-founded compliance culture. An organization's culture dictates the climate that is set, and it encompasses the guiding principles, rules, and regulations followed by personnel. If the culture within an organization does not address compliance issues, the organization is bound to end up in disarray (Kedia et al., 2016). WB must treat compliance as an important part of its strategy and work ethics; ignoring it can lead to poor business decisions, a growing number of dissatisfied clients, and constant regulatory scrutiny — all of which harm reputation and operational efficiency. WB should address these issues urgently, as they are likely to have a damaging effect on most activities within the organization (KPMG, 2008).
In addition, the internal review of operations within the division revealed training weaknesses relating to both the sales team and the Compliance and Assurance team. A lack of employee training is detrimental to the company in the long term, largely because personnel will continue to be ignorant of crucial requirements, leading to a failure to recognize breaches or violations in the conduct of service and sales agreements. Eventually, the company runs the risk of continued transgressions from personnel — even if involuntary and arising from ignorance — which can result in losses for the company.
Furthermore, it was found that there was no compliance, governance, risk, and compliance manual in use within the division. Instead, staff depended upon ad hoc guidance and information, and there was a limited level of reporting and interaction between the branches and the main Compliance and Assurance team. This is a significant concern, as it increases the likelihood of wrongdoing and misconduct. The absence of a compliance manual means that personnel and senior staff alike do not have access to the rules, regulations, and policies they should observe and adhere to (KPMG, 2008).
References
Compliance 360. (2016). White paper: The seven elements of an effective compliance and ethics program. Retrieved 1 September 2016 from http://compliance360.com/downloads/case/Seven_Elements_of_Effective_Compliance_Programs.pdf
FDIC. (2012). Compliance management system. Retrieved 3 September 2016 from https://www.fdic.gov/regulations/resources/director/college/ny/materials/2012-Compliance.pdf
Kedia, S., Luo, S., & Rajgopal, S. (2016). Culture of weak compliance and financial reporting risk. Unpublished manuscript (January 2016).
KPMG. (2008). Governance, risk, and compliance: Driving value through controls monitoring. Retrieved 3 September 2016 from
McDermott, E. (2014). Four ways to fix a broken company culture. WebPT. Retrieved 3 September 2016 from https://www.webpt.com/blog/post/four-ways-fix-broken-company-culture
Temenos. (2015). The importance of compliance training. Retrieved 3 September 2016 from
Volkov, M. (2014). Fixing a company's ethics and compliance culture. Corporate Compliance Insights.
Wulf, K. (2011). Ethics and compliance programs in multinational organizations. Springer.
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