Article Content
Overview
A Compliance Officer must record all rule breaches within the system by creating a rule breach record.
User Account Requirements
The user account used to log into Kroll's Managed Compliance Software must have Compliance Officer permission to access the Breaches section.
Related Information/Setup
Please refer to the Creating a New Breach Update for more information on updating a rule breach.
Please refer to the Closing a Completed Rule Breach for more information on closing a rule breach.
Navigation
- From the Home screen, click the Home dropdown menu.
Home Dropdown Menu
- Click the Compliance Team Portal link.
Compliance Team Portal Link
- From the Personal Trade screen, click the Breaches tab.
Breaches Tab
Creating a New Rule Breach
- From the Breaches screen, click the + Add Breach button.
+ Add Breach Button
- From the Create a New Breach screen, select the Rule Breach from the Breach Type field by clicking the radio button.
- Rule Breach: A rule breach occurs when a rule, law, or company practice or policy is broken.
Breach Type Field
- Enter a firm name in the Impacted Firm(s) field and select a firm from the dropdown menu. Users can select multiple firms.
Impacted Firm(s) Field
- (Optional) Click the X icon next to a firm name to remove the firm from the Impacted Firm(s) field.
X Icon
- Select a rule breach type from the Rule Breach Type dropdown menu.
- Outsourcing: Indicates there was a rule breach involving an outsourcing contractor.
- Conduct of Business: Indicates there was a rule breach involving the organization's business code of conduct.
- Client Assets: Indicates there was a breach involving client assets (e.g., securities, documentation, etc.)
- Gifts and Entertainment: Indicates there was a breach involving an organization's gift and entertainment policies and procedures.
- Personal Account Dealing: Indicates there was a breach involving personal account trading policies and procedures.
- Prudential: Indicates there was a breach involving prudential policies and procedures.
- Investment Mandate: Indicates there was an investment policy breach.
- Other: Covers any other breach that is not currently listed as an option.
Rule Breach Type Field
- Click the Next button.
Next Button
- Enter the date the breach was identified using the Calendar pop-up under the Date Breach Identified field, by clicking a Date.
Date Breach Identified Field
- Enter the date the breach occurred using the Calendar pop-up under the Date Breach First Occurred field, by clicking a Date.
Date Breach First Occurred Field
- Select an option to the question: Has this breach been resolved? If the user selects Yes, they must select a resolution date from the Calendar pop-up under the Date breach resolved field, by clicking a Date.
Has this Breach been Resolved? Field
- Enter the details of the breach in the Details of Breach field.
Details of Breach Field
- Enter the actions taken to resolve the breach in the Details of actions taken to resolve the breach field.
Details of Actions Taken to Resolve the Breach Field
- Select an option to the question Is regulatory notification required for this breach?
- Yes: The user must include additional information in the Please provide more details surrounding your notification to the relevant regulator field.
- No: The user must include additional information in the Please provide more details surrounding your notification to the relevant regulator field.
Is Regulatory Notification Required for this Breach? Field
- Include support documentation by dragging and dropping files into the designated area on the Attachments field or select the top proportion of the Attachments field and select a file from the connected PC.
Attachments Field
- Click the designated area on the Attachments field to add a web link. For more information on adding a web link to the project, see the Adding a Web Link article.
Web Link
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(Optional) Click the following icons to edit or delete an image from the request:
- Edit: Click the Edit icon to rename the file.
- Delete: Click the Delete icon to remove the file from the request.
Image Icons
- Click the Complete Review button.
Complete Review Button
- The rule breach will transition to a pending state. Once the breach is reported to a regulatory body (e.g. FCA) and the Compliance Officer has a breach update, the Compliance Officer must update the rule breach before it can be closed.