04 July 2016
On 25 February 2016, the Central Bank issued a letter to investment firms highlighting the results of its themed inspection on the identification and management of conflicts of interest (COI).
The Bank noted that the inspection revealed a number of failings related to the management of COI, particularly a lack of board ownership regarding their identification and management. The Bank also noted the marked differences between what it termed best-in-class and worst-in-class firms, as regards the policies and procedures these firms had in place to identify and manage COI.
Referring to culture as a driver for behaviour, the Bank noted that its themed inspection confirmed that those firms with a strong compliance culture managed COI effectively. The letter contains a (non-exhaustive) list of identified trends and both good and poor practices with regard to COI management.
The Bank requires investment firms to: