Compliance pillar tips

Audit-ready compliance management without shortcuts

These checklists fuse Zeph Tech research with COSO 2013[COSO], ISO 37301[ISO], PCAOB auditing standards[PCAOB], EU CSRD delegated acts[CSRD], DORA policy instruments[DORA], and FinCEN guidance[FinCEN].

Run them as recurring sprints so finance, risk, privacy, and sustainability teams stay synchronised with regulator expectations.

Program governance

  • Charter authority. Align compliance committee mandates with ISO 37301 clauses 5 and 6[ISO], documenting reporting lines to the board audit or risk committee.
  • Integrated risk assessment. Combine COSO enterprise risk assessment outputs[COSO] with control scoping for SOX Section 404, UK Corporate Governance Code 2024 internal control statements[FRC], and CSRD double materiality workshops[CSRD].
  • Policy lifecycle. Maintain policy inventories with approval dates, owners, and cross-references to regulatory citations; ensure changes follow documented ISO 9001-controlled procedures.

Control execution

  • Testing cadence. Schedule design and operating effectiveness testing in line with PCAOB AS 2201[AS2201] and UK FRC thematic reviews[FRC]; evidence stratified sampling results and remediation follow-up.
  • Automation validation. Evaluate automated controls, robotic process automation, and scripts with change-management tickets, code reviews, and re-performance logs mapped to ISACA COBIT control objectives[COBIT].
  • Segregation of duties. Run quarterly SoD analytics across ERP, treasury, and procurement systems, capturing mitigating controls when conflicts remain.

Documentation and evidence

  • Workpaper standards. Follow IIA Global Internal Audit Standards 2024[IIA] and AICPA audit documentation rules[AICPA] to ensure workpapers are indexed, review-noted, and retained for required periods.
  • Disclosure support. Store management representation letters, disclosure committee minutes, and ESRS tagging evidence alongside narrative controls for SEC, ESMA, and FCA filings[CSRD].
  • Beneficial ownership files. Keep FinCEN BOI submission receipts, entity structure charts, and change logs ready for 30-day update deadlines and enforcement inquiries[FinCEN].

Third-party oversight

  • Critical supplier register. Classify vendors using DORA RTS criteria[DORA RTS], EBA outsourcing guidelines[EBA], OCC Bulletin 2013-29[OCC], FDIC FIL-29-2023[FDIC], and OSFI B-10[OSFI]; tie contract clauses to reporting and exit obligations.
  • Due diligence evidence. Collect SOC 1/SOC 2 reports[SOC], ISO/IEC 27001 certificates[ISO/IEC 27001], financial statements, and sustainability attestations; record review notes and remediation commitments.
  • Continuous monitoring. Feed public sanctions lists, adverse media, and regulator enforcement bulletins into vendor risk dashboards with documented escalation paths.

Regulatory reporting

  • Submission tracker. Maintain a master calendar covering CSRD filings[CSRD], SEC Form 10-K/Q[SEC], HMRC Making Tax Digital returns[HMRC], EU ETS/CBAM reports[CBAM], and FinCEN SAR/BOI submissions[FinCEN].
  • Quality assurance. Reconcile reported metrics to general ledger, data warehouse, and ESG systems of record; document reviewer sign-off and management certifications.
  • Retention and audit trail. Archive filings, regulator correspondence, and proof-of-delivery acknowledgements for jurisdiction-specific retention periods (e.g., EU CBAM 5 years, IRS 7 years).
  • Hit 2025 Form N-CEN amendments. Follow the November 17, 2025 briefing to confirm liquidity risk management service-provider details, refreshed identifiers, and attestation evidence land in the first amended Form N-CEN cycle.

Continuous monitoring and improvement

  • Issue management. Track deficiencies from internal audit, external audit, and regulator findings through closure with root-cause analysis and target dates.
  • Training coverage. Deliver role-based compliance training aligned to DOJ Evaluation of Corporate Compliance Programs guidance, retaining completion evidence and comprehension checks.
  • Metrics and reporting. Publish dashboards covering control failure rates, regulatory submissions on time, hotline case trends, and remediation velocity for executive oversight.