Structuring a compliant organisation

Imagine that you are the compliance practitioner for First Order Financial, a well-established South African bank. The CEO, Ameerah Abrahams, has been with the company for several years. Since she started in the company, it has grown from 100 employees to 1,500 employees. Ameerah is passionate about every aspect of the business and has attempted to create, as far as possible, a flat organisational structure.

The heads of compliance, sales, marketing, and finance at First Order Financial all report to the CEO. The bank and departmental managers report to their respective leads but are also required to report to the CEO. All compliance staff have to report to each departmental manager, departmental heads, and the CEO. The structure has resulted in time-consuming and ineffective risk mitigation and a convoluted reporting structure. The CEO is also severely overworked and micromanages every aspect of the business.

What is a suitable compliance reporting structure for banks?