Shooting practice: ARROW visits

With the exception of a knock at the door from the Financial Services Authority (FSA) Enforcement team, perhaps there can be no greater challenge for a hard-pressed Compliance Officer than to prepare their firm, and in particular its senior management, for an Advanced Risk Responsive Operating frame-Work (ARROW) visit, writes Richard Burger of Reynolds Porter Chamberlain.

Richard Burger (+44 (0)20 3060 6429, Richard.Burger@rpc.co.uk) is a senior associate in the Commercial and Regulatory Group of Reynolds Porter Chamberlain LLP. He is a former FSA Enforcement lawyer and now advises clients on financial regulation and compliance issues including preparing clients for ARROW visits.

Firms that have been through an ARROW visit this year will have noticed a change in the regulator’s supervisory approach. Whereas before the FSA would have wished to ensure that a firm’s systems and controls were adequate, the current focus is on overall business strategy and, more generally, on the possibility that risks may crystallise in the future.