The increasing pressure from legislation, the supervisors and the gatekeeper function of financial institutions make the compliance framework and thus the role of compliance officer essential for financial institutions, for both large and small sized institutions. Just having a framework isn’t enough. It must also perform well in practice.

In addition, a well-designed compliance function contributes to the optimisation of a company’s business operations. Maintaining policy, ensuring proper separation of responsibilities and functions, creating awareness of risks and knowing the customers and their market contributes to a company’s success.

Setting up and optimising the compliance function and the role of compliance officer within a financial institution therefore requires both a thorough knowledge of laws and regulations, the customer base and a pragmatic attitude to actually get things done. Many financial institutions lack the time and knowledge to set up an adequate and high-quality compliance function that suits the nature and size of the institution.

Do you need support in setting up or optimising the compliance framework or the role of compliance officer? We have developed a roadmap to show how Enigma can assist you. If you have any questions, please contact one of our consultants. They will be happy to help you.

Thim Donkervoort
Legal Consultant


Design of the compliance framework

For an effective and efficient compliance function, it is important that the compliance function is an integral part of the governance of the institution. Among other things, the framework includes the correct implementation of the following:

  • All relevant legislation
  • The ‘Three lines of defence’ model
  • Creating support for the compliance department
  • Identification and implementation of an appropriate risk appetite
  • Set up risk management through operational risk analysis and systematic integrity risk analysis (SIRA)


Elaboration in procedures and work instructions

After the framework has been set up, it should be elaborated into procedures and work instructions. This is reflected in for example:

  • The CDD /KYC process
  • The transaction monitoring policy
  • Training of employees


Assessing the operation of the compliance framework

After elaboration of the compliance framework into the relevant procedures and policy documents, the assessment phase begins: are all measures effective and are the procedures and work instructions actually executed?

Important topics in this phase are:

  • Incident management policy
  • Alert handling
  • Internal audit
  • Consultation with relevant stakeholders



The compliance officer reports his findings to:

  • The relevant supervisors
  • Management / board
  • Other stakeholders internally / externally


Consultation with external stakeholders

The compliance officer is the person who liaises with external stakeholders such as the supervisors, FIU-Netherlands and interest organizations.


Through years of experience within the Payments and Compliance domain, Enigma has developed a unique and above all pragmatic step-by-step plan in which the customer is intensively guided from start to finish in setting up and performing the compliance function. The goal: contributing to sound (operational) management, as expected from an institution with a gatekeeper function.

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Our Risk & Compliance Experts

Erik van der Leer

Geert Blom

Senior Legal Adviseur
Jaap Jan de Jong

Executive Consultant
Lex van Beurden

Maarten van Denzen

Senior Legal Consultant
Peter Mulders

Executive Consultant
Roxane van der Laan

Executive Consultant
Thim Donkervoort

Legal Consultant