MCCC is a management level compliance committee headed by the organization’s CEO. The MCCC works on behalf of the Business Cooperation Contract or BCC to regularly review and provide appropriate feedback to the management and employees regarding the organization’s overall compliance profile.
MCCC is a part of the overall governance structure and the foundation of an effective AML/CFT program. It sets the compliance tone within the organization and works through the qualified Compliance Officer. In an organization such as a bank or a financial institution, the Board of Directors, through the MCCC, ensures a strong compliance culture and implements the compliance program.
As the second line of defense, the AML/CFT compliance function and the CCO are responsible for executing specific elements and regulatory requirements of the AML/CFT framework. MCCC works with the business heads to ensure compliance and create compliance awareness through the periodic MCCC meetings and ongoing training, considering the risk-based approach to managing the ML/TF risks.
CCC comprises all the departmental heads as members of the MCCC, and they meet periodically to discuss the compliance status of their respective departments. The CCO serves as the secretary to the MCCC. The CCO prepares and presents the meeting’s agenda to the CCC meeting, before the members of the MCCC, before each periodic meeting.
Management Level Corporate Compliance Committee Responsibilities
MCCC holds the overall responsibility for managing compliance risks faced by the entity and enhances the conversation with the BCC using periodic compliance reporting. Most notably, through this reporting process, the MCCC gains a better understanding of what the BCC requires and how its directions must be implemented. MCCC, through a compliance program, enriches the management dialogue by adding perspective to the strengths and weaknesses of a compliance strategy and controls.
Once the compliance program and implementation strategy are set, the MCCC provides an effective way for management to fulfill its role, knowing that the organization is attuned to risks that can impact strategy and is managing them well. Applying compliance risk management helps to create trust and instill confidence in the board, which demands greater scrutiny than ever about how compliance risks are addressed and managed.
The CCO serves as the secretary to the MCCC. The committee comprises the members from different departments or functions, such as Business, Treasury, Investments, Account Operations, Information Technology, etc.
The MCCC periodically meets to discuss and review the compliance issues, regulatory requirements, and breaches. Under the supervision of the CEO, all the members of the MCCC discuss their respective regulatory compliance requirements, issues, and possible breaches.
With the collaboration of the CCO, the CEO provides insights and directions to the members to ensure that they comply with their respective regulatory requirements.
The compliance program and its components, including policies and procedures, are reviewed and approved by the MCCC before final approval of the BCC.
During MCCC meetings, the CCO provides insight into the compliance culture and implementation of the compliance program. The MCC meetings also discuss regulatory observations, inspection reports, and compliance status.
All the members of MCCC provide support the CCO, to ensure that the compliance program is implemented effectively in the organization at all levels. MCCC ensures that the CCO of the organization is provided with sufficient resources to enable the CCO to effective implementation of the compliance program. Resources to be provided to the CCO include the appropriate Compliance and AML team, access to the information from different departments, review of the compliance status, etc.
Final Thoughts
The Management Level Corporate Compliance Committee is in charge of assessing and prioritizing legal compliance risk areas, sharing best practices in compliance programs, and developing enterprise-wide tools and monitoring mechanisms to improve the efficiency and effectiveness of company-wide compliance activities.
The Committee’s compliance risk assessment is shared annually with the senior management oversight committee and the Board of Directors’ Audit Committee.
