The movement to remote work during the early days of the COVID-19 pandemic was swift and sweeping. For regulated financial services firms, the migration to remote work required careful consideration of the compliance risks related to the use of new technologies for everything from collaboration and communication to transaction execution and customer support. While regulators broadly tolerated compliance growing pains during the abrupt and unanticipated transition process, all indications are that this grace period is now over.
Given the ongoing uncertainty about the Delta variant and the extent to which a full return to office is feasible in the coming months, regulators are issuing guidance requiring compliance controls for remote work to be equivalent those in the office. Since work from anywhere looks to be a permanent arrangement for some percentage of financial services staff, it should come as no surprise that regulators’ earlier flexibility has waned.
The FCA issued guidance in October titled “Remote or Hybrid Working Expectations for Firms,” (the “FCA Guidance”) outlining its expectations for compliance with its regulatory framework and effectively signaling the end of any reprieve for dispersed workforces. Below are a set of compliance best practices based on the FCA Guidance, which provide a roadmap for firms as they incorporate remote work protocols into their existing risk programs.