Outsourced compliance support
Without carrying it alone.

Risk-based and actually executed. A plan showing twelve reviews a year with four completed is worse evidence than a plan showing four and completing them, because it documents your own assessment of what mattered and then shows you did not do it.

Sample sizes, the criteria applied, and findings including the negative ones. Monitoring that has never produced an adverse finding is not reassuring — it reads as monitoring designed not to find anything.

Owners, dates and closure evidence, with overdue items visible rather than quietly re-dated. Root cause recorded, not just the fix, so recurrence is detectable.

Enough for the board to govern rather than be reassured: what is off track, what you are not sighted on, and what you need. A pack with no bad news invites the question of what is being filtered and by whom.

Demonstrable through budget, direct board access, and a record of escalations that were acted on. Where you were overruled, the record of you having raised it is the thing that protects both you and the firm.

A live log from publication through to implementation and evidence, with owners. Horizon scanning that produces a reading list rather than a set of actions is the version supervisors discount.

SYSC 6.1 requires adequate policies and procedures to detect the risk of failing to comply with regulatory obligations. For most firms that means an identifiable compliance function, though the FCA accepts this may be a named individual rather than a dedicated department in a smaller firm. What matters is that the function has sufficient authority, resources and independence to be effective — a compliance officer who is routinely overruled or under-resourced does not satisfy SYSC.

You can outsource the work, not the responsibility. Firms remain responsible and accountable for regulatory obligations that apply to outsourcing and third-party arrangements, and oversight remains with the firm. External support can provide expertise, monitoring or capacity, but you should retain decision ownership, enough knowledge to challenge the work, and genuine access to what is being done in your name.

It can be. The rules require effective monitoring, not particular software, and a well-run spreadsheet in a small firm can be adequate. The risks are practical rather than regulatory: version control, no audit trail of who changed what, and key-person dependency if you are the only person who understands it. The question to test is whether you could hand it to someone else tomorrow and whether it would survive a supervisory request for evidence.