In my very first job in compliance, I had the privilege of a ‘virtual’ trainer for the digital surveillance platform I was required to use, the steps for the audit I was required to undertake, and the approvals I was required to make. I place ‘virtual’ in quotation marks because this was not an actual human being delivering training through software programs like Teams, Google Chat and others. It was not even an  artificial intelligence robot (AI).  It was a detailed – Compliance Operations Manual, drafted by my predecessor.

Compliance Operations Manuals underscore the fact that business and compliance are driven by well-structured end-to-end procedures and by decisions. These well-structured procedures and decisions comprising ‘the business’ of the company, form the pathways by which the strategic business objectives of the organisation are delivered.  Documentation of such means that:

1. the business understands the importance of precision in delivery of high quality services and the importance of achieving the best outcomes in compliance. (In this way – a business is quite akin to the moving parts of an engine – moving seamlessly is the desired outcome;
2. the operations manuals can show how the compliance processs combines with the business process to comprise ‘the business’ of the company. (In this way, compliance is not viewed as a separate process but as part of the business.); and
3. compliance is shown to be a formal business process and not an arbitrary process.

Here are some advantages of Operations Manuals (non-exhaustive):

1. Operations manuals help to ensure quality assurance. A well-drafted Operations Manual shows the end-to-end pathway/mechanism by which the business and compliance operations are administered precisely and effectively.
2. Operations manuals are part of the succession plan. The pathways/mechanisms of business and compliance operations are recorded and so, they do not leave in the predecessor’s mind when he/she demits office. This allows for easier continuity when new compliance officers are instituted.
3. Operations manuals allow for transparency. The document contains the benchmarks against which auditors can easily review procedures for technical compliance and effectiveness; and so, make more insightful recommendations for improvement.
4. Where decision making is key – operations manuals should provide considerations which should be taken into account and weighed in the balance before coming to a decision.
5. Operations Manuals can and should be updated as you go along. This is especially important when anomalies highlighted in compliance audits or regulatory inspections point to anomalies which should be corrected by establishing totally new procedures, amended procedures, and/or by further education in the highlighted area.