Mat says:- Breaking the GRC Cycle: Embracing Continuous Compliance in JFSC-Regulated Firms

As someone helping those who operate under the oversight of the Jersey Financial Services Commission (JFSC) and other regulators, I've seen firsthand how governance, risk, and compliance (GRC) has evolved.

What was once a yearly or quarterly (periodic) ritual, involving comprehensive risk evaluations and structured audits, now unfolds in real time, often before the morning coffee break.

"We used to schedule risk reviews like board meetings," a Comsure client recently remarked.

"Now, they're part of the daily grind." It's barely 9:30 a.m. in Saint Helier, and the inquiries are already piling up:

• A department head is pushing to engage an outsourcing service provider. Does this trigger a full JFSC-compliant risk assessment?
• The tech team spots a potential vulnerability in our systems, but quantifying its impact isn't straightforward.
• Our auditors in the annual audit are demanding proof that a key customer risk procedure was not only documented but actively implemented across operations.

These aren't rare events anymore; they're the norm.

In Jersey's tightly regulated financial landscape, GRC has transitioned from periodic exercises to ongoing dialogues.

Yet, many firms here are still adapting to this accelerated reality, especially with the JFSC's emphasis on proactive risk management and continuous compliance monitoring.

Breaking Free from Traditional GRC Cycles

Historically, GRC in regulated entities followed a steady cadence:

• Yearly JFSC-mandated risk appraisals,
• Routine internal audits, and
• Periodic board updates.

This structure allowed ample time for data gathering, report refinement, and alignment. But that buffer has largely vanished.

• Risks materialise unexpectedly during live projects,
• Controls can falter in day-to-day operations rather than just on paper, and
• JFSC guidelines, along with broader international standards, are updated more swiftly than internal frameworks can keep pace.

A compliance officer I know summed it up well:

• "The regulatory landscape will not pause for us; it accelerated, and we're playing catch-up."

The issue isn't a shortfall in dedication or resources. It's that GRC frameworks haven't kept up with the dynamic demands of Jersey's financial sector, where real-time vigilance is now a regulatory expectation rather than an option.

The Hidden Toll of 'Adequate' Compliance

From a JFSC reporting standpoint, many organisations appear solid:

• Policies are in place,
• Risk logs are updated, and
• Audits pass muster.

But dig deeper, and the strains become evident for GRC professionals:

• Duplicate assessments of the same risk by siloed teams, wasting valuable hours.
• Compliance evidence scattered across incompatible platforms, complicating retrieval.
• Decision-making stalled while teams verify data integrity before proceeding.

This strain doesn't lead to outright collapses, but

• It generates operational drag,
• Overlooked warnings,
• Delayed responses, and
• Staff bogged down in data reconciliation instead of strategic analysis.

A compliance officer I recently met succinctly summed up the problem:

• "The core tasks are manageable; it's the endless alignment that drains us."

In Jersey, where JFSC scrutiny focuses on robust governance, this friction can erode efficiency and heighten exposure to non-compliance penalties.

The Core Issue Isn't Data, It's Integration

Few JFSC-regulated firms lack GRC information; the problem lies in its fragmentation.

• Risk insights reside in one database,
• Control validations in another, and
• Audit outcomes in yet a third.

Each piece offers a fragment of the picture, but synthesising them requires manual intervention.

This disconnects, hampers momentum, and undermines trust.

When senior leaders or JFSC inspectors pose straightforward queries like "How effectively is this risk mitigated?" or "What shifts have occurred since the last review?", responses drag on, not due to ignorance, but because our systems aren't built for seamless integration.

Enhancing this connectivity is crucial to maintaining the JFSC's standards of transparent, agile risk governance.

Effective GRC: Subtle Yet Empowering

In the most advanced GRC setups, those fully aligned with JFSC principles, the process doesn't feel burdensome or obstructive. Instead, it's seamless and supportive.

Potential issues flag themselves promptly, deviations are transparent rather than concealed, and discussions rely on unified, reliable data. Here, GRC doesn't hinder business momentum; it bolsters it, enabling informed, swift decisions that comply with regulatory demands.

An industry peer observed: "Strong GRC doesn't demand attention; it provides peace of mind."

Achieving this requires viewing GRC not as a static annual obligation but as an adaptive ecosystem. In Jersey's regulated environment, this means embedding continuous monitoring, fostering cross-functional collaboration, and leveraging integrated tools to meet JFSC expectations without unnecessary overhead. It's about making compliance a natural extension of daily operations, ensuring resilience in an ever-shifting world.

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For more information: please contact-  Mathew Beale - Chartered FCSI, Principal & Director - Comsure Compliance Limited, Comsure Technology Limited, Comsure Mauritius (the "Comsure Group of Companies")

mathewbeale@comsuregroup.com-www.comsuregroup.com  

T (Jersey) +44 1534 733-588 /+44 7797 747-490