THE CHALLENGE
A new compliance system had been implemented before its controls and data had been fully validated.
The firm's new compliance management system had been onboarded without comprehensive testing or parallel implementation alongside the legacy system. Following migration, employee account, holdings and transaction data contained inaccuracies, while trading rules and system configurations required further review and refinement.The challenge was not simply correcting individual errors. It was establishing confidence that the system could reliably support ongoing compliance oversight.
THE INVESTIGATION
Understanding where the system was breaking down.
The work began with a comprehensive audit of the platform, examining how data moved through the system, how compliance rules were configured and where discrepancies were being introduced.
01
SYSTEM CONFIGURATION
- User roles & permissions
- Trading rule logic
- Workflow configurations
02
DATA INTEGRITY
- Custodian data feeds
- Accounts, holdings & transactions
- Brokerage statement reconciliation
03
CONTROL ENVIRONMENT
- Exception alerts & reports
- Pre-clearance workflows
- Reconciliation processes
THE GOAL
Identify where system configuration, incoming data and compliance controls were falling out of alignment.
THE STRATEGY
Move from post-implementation troubleshooting to structured system governance.
The approach combined vendor management, end-to-end system testing, data reconciliation and rule optimization to address immediate inaccuracies while establishing a more sustainable control environment.
01 | Validate
02 | govern
03 | sustain
Test account feeds, holdings, transactions, trading rules, pre-clearance workflows and reporting from end to end.
Establish clearer vendor responsibilities, communication channels, escalation procedures and issue tracking.
Introduce documentation, version control, recurring testing, monitoring dashboards and periodic system reviews.
The Execution
Turning remediation into ongoing governance.
01
Conducted a comprehensive audit of user roles, data feeds, rule logic and workflow configurations.
02
Compared system-generated reports and exception alerts against brokerage statements to identify discrepancies.
03
Performed a full reconciliation of employee accounts, holdings and transactions.
04
Established regular vendor meetings, defined responsibilities, escalation procedures and ongoing issue tracking.
05
Conducted end-to-end testing across account feeds, trading rules, pre-clearance workflows and reporting.
06
Reassessed system rules and introduced stronger documentation and version control.
07
Established recurring testing, monitoring dashboards and periodic reporting to support continuous oversight.
THE IMPACT
From an unreliable implementation to a more controlled and continuously monitored compliance system.
✓ Improved accuracy of compliance data
✓ More reliable reporting and disclosures
✓ Stronger vendor governance
✓ Greater transparency into system issues
✓ More efficient issue resolution
✓ Recurring testing and monitoring established
✓ Continuous system improvement embedded into the process
CONTINUOUS
TESTING & MONITORING
ESTABLISHED AS AN ONGOING CONTROL
LEADERSHIP TAKEAWAY
“Effective compliance technology isn't implemented once. It requires governance, validation and continuous improvement.”
The transformation of a compliance platform is often viewed as a single event—a moment when a new system is 'turned on.' However, the real work begins with governance. By establishing continuous testing cycles, clear vendor accountability and a structured issue-remediation process, we moved the program from a state of post-implementation troubleshooting to a state of sustainable, high-integrity operation.
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Sands Capital Management
Guggenheim Investments