Sustaining MaRisk Compliance on an Ongoing Basis

Ongoing compliance refers to the continuous adherence to Minimum Requirements for Risk Management (MaRisk) beyond initial implementation. It involves regular monitoring, updating of processes, and adaptation to new regulatory requirements to ensure permanent audit readiness.

MaRisk compliance should be reviewed continuously, with formal reviews conducted at least annually. Additionally, ad-hoc reviews are necessary whenever there are significant changes in business activities, risk strategies, or regulatory frameworks.

Key challenges include keeping up with frequent regulatory updates, ensuring consistent implementation across all business units, managing data quality for risk reporting, and maintaining adequate resources and expertise for compliance tasks.

Technology can automate monitoring processes, ensure data consistency, and facilitate efficient reporting. RegTech solutions can also help track regulatory changes and map them to internal controls, reducing manual effort and the risk of non-compliance.

The compliance function acts as a second line of defense, responsible for monitoring adherence to legal and regulatory requirements. It advises management, identifies compliance risks, and ensures that effective control processes are in place and functioning correctly.

Self-assessments are a central instrument for the continuous monitoring and improvement of MaRisk compliance. However, they are often perceived as a bureaucratic obligation that consumes significant resources without delivering corresponding value. ADVISORI supports you in transforming your self-assessment processes into an effective strategic instrument that delivers genuine insights and drives improvements. Methodological foundations of effective self-assessments: Risk-oriented prioritization: Development of a differentiated approach that aligns the frequency, depth, and scope of self-assessments with the risk relevance of the respective MaRisk requirements and organizational units. Balance between standardization and flexibility: Creation of a framework that combines uniform guiding principles with area-specific customization options, ensuring both relevance and comparability. Process orientation instead of checklist mentality: Transition from isolated control questions to process-oriented assessments that consider the entire compliance lifecycle and account for interdependencies between different requirements. Evidence-based evaluation: Establishment of clear criteria and documentation requirements for assessing compliance, minimizing subjective judgments and promoting fact-based evaluation.

A risk-oriented approach to MaRisk compliance is both regulatorily required and operationally sound. Rather than addressing all requirements with equal intensity, it enables the concentration of resources on the material risk areas of your institution. ADVISORI supports you in developing and implementing a tailored risk-oriented compliance approach that meets regulatory expectations while significantly enhancing your compliance efficiency. Foundations of a risk-oriented MaRisk compliance approach: Compliance risk assessment framework: Development of a structured methodology for evaluating compliance risks that considers both inherent risk factors and the quality of existing controls. Risk segmentation: Categorization of MaRisk requirements according to their risk relevance for your specific business model, organizational structure, and system landscape. Proportionality principles: Elaboration of clear criteria for applying the supervisory proportionality principle, enabling an appropriate, risk-oriented implementation of MaRisk. Dynamic risk reassessment: Establishment of a process for the continuous reassessment of compliance risks based on internal and external changes, audit findings, and incidents.

The integration of MaRisk compliance and outsourcing management is becoming increasingly important for financial institutions, as outsourcing arrangements offer both opportunities for efficiency gains and significant compliance risks. ADVISORI supports you in developing an integrated approach that fulfils regulatory requirements while simultaneously ensuring operational efficiency. Integrated Governance Structures: Harmonised Outsourcing and Compliance Framework: Development of a coherent framework that smoothly connects outsourcing management and MaRisk compliance, defining clear responsibilities, processes and controls. Coordinated Committee Structure: Design of an efficient governance structure that addresses both outsourcing and compliance aspects, avoiding unclear responsibilities or duplicate structures. End-to-End Outsourcing Process: Integration of compliance checkpoints into all phases of the outsourcing lifecycle — from decision-making through initiation and implementation to ongoing monitoring and termination. Third-Party Risk Management: Establishment of a comprehensive approach to managing third-party risks that encompasses regulatory, operational, financial and reputational aspects. Risk-Based Management of Outsourcing Arrangements: Integrated Risk Assessment Methodology: Development of a structured approach to assessing outsourcing risks that takes into account both MaRisk-specific and general risk aspects.

The optimal organisation and dimensioning of the MaRisk compliance function is a central challenge for financial institutions. A function that is too small or inadequately positioned can increase compliance risks, while an oversized structure generates unnecessary costs. ADVISORI supports you in developing a tailored, effective and efficient compliance organisation that is suited to your business model and risk profile. Organisational Positioning and Governance: Governance Design: Development of an optimal organisational embedding of the compliance function within the three lines of defence, with clear demarcation from other control and monitoring functions. Responsibilities and Accountability Matrix: Creation of a detailed RACI matrix that clearly defines responsibilities and interfaces between compliance, risk management, internal audit and operational units. Reporting Lines: Design of appropriate direct reporting lines from the compliance function to senior management that ensure independence while also guaranteeing effective communication channels. Interface Management: Development of efficient cooperation and exchange models with other control functions (risk management, legal, internal audit) to avoid duplication of effort and information gaps.

An effective compliance monitoring system is the cornerstone of sustainable MaRisk compliance. It enables the systematic monitoring of regulatory conformity, the early detection of weaknesses and the targeted management of improvement measures. ADVISORI supports you in developing and implementing a tailored monitoring approach that both meets regulatory requirements and is operationally efficient to implement. Strategic Alignment and Framework Concept: Compliance Monitoring Framework: Development of a comprehensive framework that clearly defines the objectives, guiding principles, responsibilities and core processes of compliance monitoring. Risk-Based Focus: Support in prioritising monitoring activities based on a systematic assessment of compliance risks across various business areas and processes. Multi-Tiered Monitoring Concept: Design of a differentiated approach with various monitoring levels, ranging from continuous baseline controls and regular reviews through to more in-depth periodic assessments. Integrated Management Cycle: Development of a closed control loop that systematically connects the planning, execution, evaluation and follow-up of monitoring activities. Methodological Components and Instruments: Compliance Control.

An integrated Governance, Risk and Compliance (GRC) framework offers significant opportunities to make MaRisk compliance more efficient, effective, and value-generating. By systematically interlinking governance structures, risk management, and compliance activities, synergies can be unlocked, resources optimised, and strategic added value generated. ADVISORI supports you in developing and implementing a tailored GRC approach that elevates your MaRisk compliance to a new level. Strategic Integration and Synergies: Harmonised Objectives: Development of an integrated target picture that aligns the various GRC areas towards common strategic goals and overcomes siloed thinking. Process Integration: Identification and realisation of synergies between compliance, risk management, and governance processes that reduce duplication of effort and increase efficiency. Consolidated Operating Model: Establishment of a comprehensive operating model that optimally allocates and utilises resources, competencies, and capacities across various GRC functions. Integrated Methodology Base: Development of shared methodological foundations for the various GRC disciplines, from risk analyses and control testing through to measures management.

Continuous improvement is a fundamental principle of sustainable MaRisk compliance management. Given evolving regulatory requirements, changing business models, and increasing efficiency expectations, the systematic further development of your compliance structures and processes is critical to long-term success. ADVISORI supports you in establishing a structured continuous improvement approach for your MaRisk compliance. Strategic Framework for Continuous Improvement: Compliance Excellence Vision: Development of a clear, motivating target picture for your MaRisk compliance that goes beyond mere rule conformity and encompasses efficiency, effectiveness, and value contribution. Maturity Model Approach: Implementation of a maturity model for various dimensions of your MaRisk compliance that assesses the current state, defines development targets, and makes progress measurable. Innovation Framework: Establishment of a structured framework for the continuous identification, evaluation, and implementation of effective approaches in compliance management. Resource Roadmap: Development of a long-term plan for the allocation of resources to improvement initiatives that takes into account both quick wins and strategic transformations.