In a recent circular dated January 31, 2024, DoS.CO.CSITEG.SEC.No.9/31-01-015/2023-24, the Reserve Bank of India has issued a directive to regulated entities within the financial sector. The mandate is to streamline and automate various facets of the compliance function, placing a strong emphasis on eliminating manual intervention.

This directive follows a pivotal speech by Shri Swaminathan J., Deputy Governor of RBI, during the Heads of Assurance functions conference on January 10, 2024, where Chief Compliance Officers of banks were also key participants. Shri Swaminathan stressed the independent roles of Assurance Functions, including Compliance Function, Risk Management Function, and Internal Audit Function. The aim is, rightly, to ensure that assurance activities are carried out with unwavering integrity, objectivity, and effectiveness!

The combined essence of these communications is crystal clear. Regulated entities are mandated to embrace automation in various compliance activities, utilizing tools and mechanisms. Notably, the directive underscores the creation of a unified dashboard tailored for Senior Management, providing a holistic overview of the organization’s compliance status.

Importantly, the call for enterprise-wide solutions does not necessarily mean a one-size-fits all approach. Rather, it recognizes the diverse nature of entities, each with its unique products, services, and operational nuances. The directive acknowledges that while enterprise-wide solutions are encouraged, flexibility is paramount to cater to the distinct requirements and processes of individual entities.

An essential and foundational step for timely automating compliance monitoring lies in immediate identification of numerous regulatory and statutory compliance obligations. This urgency arises because the configuration and parameterization of any automated systems must account for the diversity and applicability of compliance obligations across various functions and operating environments within regulated entities.

The identification process assumes a level of functional expertise to accurately interpret apparent regulatory expectations and the underlying objectives. Regulated entities may find it beneficial to explore outsourcing this critical aspect to reputable entities with a proven track record in maintaining reliable repositories of regulatory and statutory compliance obligations. Such entities can also provide timely updates in response to the ever-evolving landscape of regulatory requirements. The strategic outsourcing not only enables entities to tap into specialized knowledge but also establishes a robust compliance framework and seamlessly aligns with the dynamic regulatory environment.

Also, the integration of suitable indigenous solutions and tools for different facets of compliance management by entities offering repositories of regulatory and statutory obligations may prove to be highly advantageous, and in line with the current philosophy of the Government of India for ultimate betterment of India’s growth. Unlike generic high-priced products that require subsequent configuration / programming spread over several months for diverse aspects of compliance management across vastly varying business/operating processes, these tools are specifically designed to fulfil specific regulatory compliance management obligations. This tailored approach ensures a more effective and efficient alignment with the intricate and dynamic requirements of regulatory compliance. The synergy between specialized tools and expertly maintained repositories further enhances the capability of regulated entities to navigate the complexities of compliance management seamlessly.

The reiteration to keep Audit, Compliance, and Risk as independent pillars of assurance is also noteworthy. This also necessitates independent automation of each function keeping in view different objectives, data points, and analytical tools required for automation of each such function.

RBI’s renewed emphasis on bringing automation to compliance management across entire financial sector and regulated entities, irrespective of organizational size, entity type, and diversity of its business activities (small or large), is a welcome and assertive step in strengthening India’s march towards a resilient and compliant banking system!

After all, India, being the world’s largest IT powerhouse, has enough expertise in the country with our home-grown institutions to cater to regulator’s need keeping in mind the robust regulatory vigilance rather than be influenced by MNCs and their own sweet interpretation of our regulator’s intent and expectations. There would not be a better time to leverage and adopt expertise and content-backed technology from our own backyard!

(Prem Gursahani is a veteran banker with 50+ years of hands-on experience in banking as part of the country’s largest bank, banking consulting, regulatory consulting, and process management. He is routinely invited to share his views and expertise with the regulator on key banking matters. He is the founder of Alpha Plus Group which specializes in regulatory technology focused on knowledge, compliance automation, and business process automation with a focus on regulatory content.)

Disclaimer: The views expressed in this article are of the author based on his experience and do not necessarily express views of the company or any regulator.