Interview: Glenn Seah – Head of Legal, Compliance & Company Secretary’s Office at SGX
Glenn Seah is the Head of Legal, Compliance & Company Secretary’s Office at SGX. With extensive experience in financial regulation and litigation in Asia Pacific, Glenn joins a panel discussion on Regulatory Compliance Risk Assessment at the IAS Singapore on September 8th.Hi Glenn. You’ll be participating in a panel discussion at the IAS Singapore. What do you hope to bring to the fore in your discussion on ‘Regulatory Compliance Risk Assessment’?
The volume of regulation is mind-boggling, and it seems that with each new month, some regulator somewhere in the world adds to the compendium. While the willingness of boards and management to address Compliance issues has certainly increased, the resources available to control functions are not unlimited. In an environment where the financial industry continues to deleverage, it makes more sense than ever before to adopt a risk-based approach in allocating Compliance resources.
But the value of risk assessment is not only one of efficient resource allocation. Risk management is only useful if it is forward-looking. A Compliance risk assessment provides a platform for companies to take a clear-eyed look at what the Compliance risks are in the first place. It is a time to pause, look up from the daily firefighting, pro-actively anticipate what risks are emerging, and respond accordingly. Efficient resource allocation is just one aspect. An effective risk assessment leads to other important outcomes as well – how are the Compliance and control teams organised? What kinds of management information can better inform us about the risks we have identified? What systems and processes need to change to meet the anticipated regulatory expectations?SGX announced its decision to restructure at the end of 2015. How has this impacted the efficiency and effectiveness of the company?
The Legal, Compliance and Company Secretary’s Office remain distinct functions, but reporting of these three functions to myself has been consolidated. The re-organization has facilitated three main things:
Ownership of the relationships with SGX’s regulators in Singapore and overseas, including regulatory applications, has been better consolidated. We believe the reduction of silos is a significant mitigant against the risk of issues falling between the cracks, and the flip side risk of unnecessary duplication of control effort.
Consolidation facilitates a strong control voice at senior management level. This is invaluable in promoting a robust culture of controls and governance at the top, which in turn translates to strong “tone at the top” messaging through all the other levels.
From a human capital point of view, consolidation creates scale and efficiency. Staff are exposed to a broader array of work, which fosters accelerated development, and better contextualized advice for the business.
New regulations have a life cycle. Inception is sometimes planned, but other times not! What follows is more predictable – gestation and development, followed by an often painful birth, initial growing pains, then maturity, and then the cycle restarts. It’s important, wherever practicable, to manage and influence each stage. In this regard, inter-departmental collaboration is essential.
During the gestational period of a new regulation, it is our responsibility to provide constructive, practical feedback to the regulators.This process of inter-departmental iteration continues at each successive stage as regulation comes into force, matures and then evolves. New issues come up, and better ways of doing things become apparent. But all of this can only happen if Compliance descends from the ivory tower and work together with other stakeholders to understand the issues.What is the biggest change you’ve witnessed in the field of Compliance?
I could highlight all sorts of interesting developments, from the messiness of cross-border regulation to the recent rise of financial crime compliance. But I would say that the biggest change has been the emergence of independent Compliance as a discipline. To my mind, this is a reflection of two things – one, the increasing complexity and inherent dangers of the modern business environment, which has necessitated technically competent, strong character Compliance types to protect the company; and two, a growing acceptance of the social compact that to do right is a great way to do well. I think the underlying morality of the Compliance profession makes it a personally fulfilling career choice for many people.How do you see technological advances impacting the Compliance field?
One of the hottest topics today is FinTech, and within FinTech, there is a white-hot supernova called Blockchain. At the current rate of growing hype, we’ll soon have Blockchain eliminating world hunger!
I think that it all comes back to information, and how we analyze and use it; Blockchain is just one example. I’ve been very impressed with how some of my counterparts in various financial institutions have been harnessing data analytics to detect and respond to fraud, mis-selling and market misconduct. Ploughing through big data and gleaning actionable intelligence is going to be increasingly important in the years to come.What are the most significant factors impacting risk assessment today?
I’ve mentioned a number of factors – the need to look up from fire fighting; the need for an organization that facilitates holistic, rather than siloed responses; and the value of technology. But in the end, nothing works if you don’t have the right people. People who buy in that effective risk assessment make the company stronger and more successful; people who are serious about looking forward; people who are passionate about working hand-in-hand to do right and do well; and yes, people who genuinely want to learn and improve, and attend conferences like this!