Connecting compliance technology
to effective programs.

ICRM assisted in product development, helping align intended product outcomes with regulatory requirements, the compliance program and internal control environment of the client, and the needs of compliance practitioners. The focus was on connecting the question “What can the technology do?” with “What does the compliance program need it to accomplish?”

That perspective helped connect product capabilities with the control objectives, information and decision processes they were intended to support.

ICRM’s advisory work also focused on how institutions could incorporate technology into effective compliance programs. This meant considering the surrounding operating environment: data quality, risk assessment, screening practices, review processes, accountability and oversight.

The emphasis was on technology functioning as part of an internal control system, with appropriate human judgment and clear ownership of decisions and follow-up.

ICRM brought particular attention to the relationship between reliable data and meaningful compliance outcomes. The focus of ICRM’s work and industry experience addressed subjects including sanctions screening, customer risk, beneficial ownership and the importance of data quality.

These subjects are interconnected. Weak or incomplete information can undermine a sophisticated solution; reliable information must still be interpreted and acted upon within an appropriate control framework.