We recently reviewed the compliance function in wholesale banks. This note summarises what we were told and some of our own observations. We also include more detailed information from our questionnaire.
August 2025 update: This review is historical. See our what we publish[1] page for more information and current views.
Read the compliance function in wholesale banks (PDF)[2]
In January this year, we sent a questionnaire to 22 wholesale banks asking for information about their compliance function. This exercise was designed to give us greater insight into the changes in the function over the past few years and where further challenges remain.
The questionnaire contained 27 questions about the compliance function covering the following topics:
- Role and structure
- Strategy and planning
- Compliance monitoring
- Technology
- Support and challenge
- Personnel
The 22 firms in our sample included large global banks operating across several business lines, medium-sized firms who focus more on specific areas or geographies and firms with less significant UK footprints. We are grateful for the contributions made by each of the respondents to our questionnaire.
The key themes and issues arising from the responses are set out in our report along with some of our own observations.
We are not asking individual firms to take any specific action in response to this publication. But firms and heads of compliance may find the contents helpful in developing their departments. We have included a series of questions at the end of the summary section that boards and senior management might pose to themselves.