6. Bibliography

Basel Committee. 2015. Guidelines: corporate governance principles for banking. Available: https://www.bis.org/bcbs/publ/d328.htm [2020, November 18].

Davies, H. & Zhivitskaya, M. 2018. Three lines of defence: a robust organising framework, or just lines in the sand? Global Policy. 9(S1):34-42. DOI: https://doi.org/10.1111/1758-5899.12568.

Fox, T. 2015. Victory or death: William Barret Travis and the obligations of a CCO. Available: https://www.jdsupra.com/legalnews/victory-or-death-william-barret-travis-61029 [2020, February 18].

Kubitscheck, V. 2016. Integrated assurance: risk governance beyond boundaries. New York: Routledge.

Sandler, R. 2020. Bloomberg once blamed the financial crisis on rules that prevented racial discrimination in real estate. Available: https://www.forbes.com/sites/rachelsandler/2020/02/13/bloomberg-once-blamed-the-financial-crisis-on-rules-that-prevented-racial-discrimination-in-real-estate/#5c0a7067a540 [2020, February 18].

Ward, S. 2016. The changing face of compliance: managing regulatory risk. New York, NY: Routledge.

Resourcing as a barrier to independence

In this unit's set of notes, you learnt about some of the problems associated with under-resourcing in the compliance function. There is, however, also the issue of over-resourcing. The Module 1 Unit 1 notes highlighted the increasing complexity of regulatory universes. As a result, some organisations have created extensive protective measures against regulatory risks. McKinsey & Company provide an analysis, accompanied by data, of over-resourcing in the financial industry.

In this small group discussion forum, discuss which aspects of the findings you found most surprising. In your post, pay specific attention to where the compliance function is positioned in the lines of assurance model and how the compliance function is affected by over-resourcing.