MaRisk Ongoing Compliance

Ongoing compliance refers to the continuous adherence to Minimum Requirements for Risk Management (MaRisk) beyond initial implementation. It involves regular monitoring, updating of processes, and adaptation to new regulatory requirements to ensure permanent audit readiness.

MaRisk compliance should be reviewed continuously, with formal reviews conducted at least annually. Additionally, ad-hoc reviews are necessary whenever there are significant changes in business activities, risk strategies, or regulatory frameworks.

Key challenges include keeping up with frequent regulatory updates, ensuring consistent implementation across all business units, managing data quality for risk reporting, and maintaining adequate resources and expertise for compliance tasks.

Technology can automate monitoring processes, ensure data consistency, and facilitate efficient reporting. RegTech solutions can also help track regulatory changes and map them to internal controls, reducing manual effort and the risk of non-compliance.

The compliance function acts as a second line of defense, responsible for monitoring adherence to legal and regulatory requirements. It advises management, identifies compliance risks, and ensures that effective control processes are in place and functioning correctly.

Self-assessments are a central instrument for the continuous monitoring and improvement of MaRisk compliance. However, they are often perceived as a bureaucratic obligation that consumes significant resources without delivering corresponding value. ADVISORI supports you in transforming your self-assessment processes into an effective strategic instrument that delivers genuine insights and drives improvements. Methodological foundations of effective self-assessments: Risk-oriented prioritization: Development of a differentiated approach that aligns the frequency, depth, and scope of self-assessments with the risk relevance of the respective MaRisk requirements and organizational units. Balance between standardization and flexibility: Creation of a framework that combines uniform guiding principles with area-specific customization options, ensuring both relevance and comparability. Process orientation instead of checklist mentality: Transition from isolated control questions to process-oriented assessments that consider the entire compliance lifecycle and account for interdependencies between different requirements. Evidence-based evaluation: Establishment of clear criteria and documentation requirements for assessing compliance, minimizing subjective judgments and promoting fact-based evaluation.

Integrating MaRisk compliance into a comprehensive Governance, Risk & Compliance (GRC) framework is a strategic lever for leveraging synergies, avoiding redundancies, and enhancing the effectiveness of compliance activities. ADVISORI supports you in establishing a smooth connection between your MaRisk-specific compliance requirements and your overarching GRC approach — ensuring both regulatory conformity and operational efficiency. Integrated governance structures: Harmonized governance model: Development of a coherent governance architecture that connects MaRisk-specific requirements with overarching GRC structures and defines clear, non-redundant accountabilities. Aligned committee landscape: Optimization of your committee and governance body structure to avoid parallel structures while ensuring MaRisk-specific governance requirements are met. Integrated escalation process: Establishment of a uniform, tiered escalation mechanism for all GRC topics that accounts for the specific requirements of MaRisk (e.g., ad hoc reporting to the Management Board and Supervisory Board). Coordinated mandating: Creation of aligned mandates and rules of procedure for compliance, risk, and governance functions that minimize overlaps and close accountability gaps.

A risk-oriented approach to MaRisk compliance is both regulatorily required and operationally sound. Rather than addressing all requirements with equal intensity, it enables the concentration of resources on the material risk areas of your institution. ADVISORI supports you in developing and implementing a tailored risk-oriented compliance approach that meets regulatory expectations while significantly enhancing your compliance efficiency. Foundations of a risk-oriented MaRisk compliance approach: Compliance risk assessment framework: Development of a structured methodology for evaluating compliance risks that considers both inherent risk factors and the quality of existing controls. Risk segmentation: Categorization of MaRisk requirements according to their risk relevance for your specific business model, organizational structure, and system landscape. Proportionality principles: Elaboration of clear criteria for applying the supervisory proportionality principle, enabling an appropriate, risk-oriented implementation of MaRisk. Dynamic risk reassessment: Establishment of a process for the continuous reassessment of compliance risks based on internal and external changes, audit findings, and incidents.

The digitalization of MaRisk compliance offers significant advantages for financial institutions: it reduces manual effort, minimizes error risks, improves traceability, and enables data-driven compliance decisions. ADVISORI supports you in the systematic digitalization of your MaRisk compliance management with a comprehensive approach that equally considers people, processes, and technology. Strategic analysis and transformation planning: Digital maturity assessment: Systematic evaluation of the digital maturity of your existing MaRisk compliance processes and systems, and identification of digitalization potentials. Digitalization strategy: Development of a comprehensive roadmap for the digital transformation of your compliance management with clear priorities, milestones, and ROI considerations. Technology selection framework: Creation of structured evaluation criteria for selecting suitable GRC technologies based on your specific requirements, IT strategy, and regulatory requirements. Change management concept: Development of an integrated approach that brings people along in the transformation process and creates the organizational prerequisites for successful digitalization. Solution selection and implementation: Requirements management: Systematic collection and prioritization of functional and non-functional requirements for your digital MaRisk compliance solution, incorporating all relevant stakeholders.

The regular amendments to MaRisk present financial institutions with recurring challenges. A structured and efficient implementation of new regulatory requirements is critical to minimizing compliance risks while optimizing implementation effort. ADVISORI supports you with a proven, multi-stage approach to the systematic preparation and implementation of MaRisk amendments. Early analysis and strategic preparation: Regulatory impact assessment: Detailed analysis of new MaRisk requirements and their specific implications for your institution, taking into account your business model and organizational structure. Gap analysis: Systematic comparison of new requirements with your existing processes, policies, and controls to precisely identify areas requiring action. Measures planning: Development of a structured implementation plan with clear accountabilities, realistic timelines, and efficient resource allocation. Stakeholder management: Early involvement and communication with all relevant stakeholders, from the Management Board through specialist departments to IT and external service providers. Methodological implementation support: Workstream organization: Establishment of an effective project structure with thematic workstreams that enable the parallel processing of various requirement areas.

Branch banks and subsidiaries of foreign institutions face specific challenges in MaRisk compliance. They must meet both German requirements and the regulations of their home country and group — often with limited local resources. ADVISORI supports you with tailored approaches that take these particular framework conditions into account and develop pragmatic, proportionate solutions. Multi-Regulatory Management: Regulatory Mapping: Creation of structured comparative analyses between MaRisk requirements and the regulations of the home country (e.g. EBA Guidelines, PRA requirements, Fed requirements) to make commonalities and differences transparent. Group-Local Alignment: Development of approaches to harmonise local MaRisk requirements with group-wide guidelines and compliance structures while maintaining local regulatory conformity. Equivalence Analyses: Support in assessing the extent to which group policies and processes can be recognised as equivalent to German MaRisk requirements in order to avoid duplication of effort. Compliance Bridge Concepts: Development of bridge solutions that complement existing group frameworks with specific MaRisk requirements, thereby ensuring efficient overall conformity.

Financial institutions today face a multitude of overlapping regulatory requirements. In addition to MaRisk, they must simultaneously comply with BAIT, ZAIT, GDPR, KWG, WpHG and numerous other regulatory frameworks, which considerably increases the complexity of compliance management. ADVISORI supports you in understanding these regulatory interactions and developing an integrated, efficient compliance management system. Comprehensive Regulatory Mapping: Multi-Regulatory Requirements Analysis: Systematic identification and structuring of overlapping requirements from various regulatory frameworks (MaRisk, BAIT, GDPR, etc.) to create a comprehensive overview. Compliance Intersection Matrix: Development of a detailed matrix that transparently visualises the overlaps, complements and potential conflicts between various regulatory requirements. Regulatory Hierarchy Framework: Development of a clear understanding of the hierarchy and relationships between various regulatory frameworks as a basis for prioritisation and implementation decisions. Gap-Consolidation Analysis: Identification of gaps and redundancies in the implementation of various regulatory requirements in order to identify focus areas for optimisation. Integrated Compliance Planning and Management: Consolidated Regulatory Change Process: Development of a comprehensive approach to identifying, assessing and implementing regulatory changes across various regulatory frameworks.

The integration of MaRisk compliance and outsourcing management is becoming increasingly important for financial institutions, as outsourcing arrangements offer both opportunities for efficiency gains and significant compliance risks. ADVISORI supports you in developing an integrated approach that fulfils regulatory requirements while simultaneously ensuring operational efficiency. Integrated Governance Structures: Harmonised Outsourcing and Compliance Framework: Development of a coherent framework that smoothly connects outsourcing management and MaRisk compliance, defining clear responsibilities, processes and controls. Coordinated Committee Structure: Design of an efficient governance structure that addresses both outsourcing and compliance aspects, avoiding unclear responsibilities or duplicate structures. End-to-End Outsourcing Process: Integration of compliance checkpoints into all phases of the outsourcing lifecycle — from decision-making through initiation and implementation to ongoing monitoring and termination. Third-Party Risk Management: Establishment of a comprehensive approach to managing third-party risks that encompasses regulatory, operational, financial and reputational aspects. Risk-Based Management of Outsourcing Arrangements: Integrated Risk Assessment Methodology: Development of a structured approach to assessing outsourcing risks that takes into account both MaRisk-specific and general risk aspects.

The optimal organisation and dimensioning of the MaRisk compliance function is a central challenge for financial institutions. A function that is too small or inadequately positioned can increase compliance risks, while an oversized structure generates unnecessary costs. ADVISORI supports you in developing a tailored, effective and efficient compliance organisation that is suited to your business model and risk profile. Organisational Positioning and Governance: Governance Design: Development of an optimal organisational embedding of the compliance function within the three lines of defence, with clear demarcation from other control and monitoring functions. Responsibilities and Accountability Matrix: Creation of a detailed RACI matrix that clearly defines responsibilities and interfaces between compliance, risk management, internal audit and operational units. Reporting Lines: Design of appropriate direct reporting lines from the compliance function to senior management that ensure independence while also guaranteeing effective communication channels. Interface Management: Development of efficient cooperation and exchange models with other control functions (risk management, legal, internal audit) to avoid duplication of effort and information gaps.

An effective compliance monitoring system is the cornerstone of sustainable MaRisk compliance. It enables the systematic monitoring of regulatory conformity, the early detection of weaknesses and the targeted management of improvement measures. ADVISORI supports you in developing and implementing a tailored monitoring approach that both meets regulatory requirements and is operationally efficient to implement. Strategic Alignment and Framework Concept: Compliance Monitoring Framework: Development of a comprehensive framework that clearly defines the objectives, guiding principles, responsibilities and core processes of compliance monitoring. Risk-Based Focus: Support in prioritising monitoring activities based on a systematic assessment of compliance risks across various business areas and processes. Multi-Tiered Monitoring Concept: Design of a differentiated approach with various monitoring levels, ranging from continuous baseline controls and regular reviews through to more in-depth periodic assessments. Integrated Management Cycle: Development of a closed control loop that systematically connects the planning, execution, evaluation and follow-up of monitoring activities. Methodological Components and Instruments: Compliance Control.

An integrated Governance, Risk and Compliance (GRC) framework offers significant opportunities to make MaRisk compliance more efficient, effective, and value-generating. By systematically interlinking governance structures, risk management, and compliance activities, synergies can be unlocked, resources optimised, and strategic added value generated. ADVISORI supports you in developing and implementing a tailored GRC approach that elevates your MaRisk compliance to a new level. Strategic Integration and Synergies: Harmonised Objectives: Development of an integrated target picture that aligns the various GRC areas towards common strategic goals and overcomes siloed thinking. Process Integration: Identification and realisation of synergies between compliance, risk management, and governance processes that reduce duplication of effort and increase efficiency. Consolidated Operating Model: Establishment of a comprehensive operating model that optimally allocates and utilises resources, competencies, and capacities across various GRC functions. Integrated Methodology Base: Development of shared methodological foundations for the various GRC disciplines, from risk analyses and control testing through to measures management.

Internal Audit plays a decisive role in the Three-Lines-of-Defense model of MaRisk compliance. As an independent audit body, it must regularly and systematically review the effectiveness and appropriateness of compliance processes and controls. ADVISORI supports both Internal Audit in conducting effective MaRisk audits and the audited units in optimally preparing for such audits. Strategic Audit Planning and Preparation: Risk-Based Audit Planning: Support in developing a risk-oriented audit plan that prioritises MaRisk-relevant areas according to their criticality, rate of change, and regulatory relevance. Audit Universe Development: Support in systematically capturing and categorising all audit-relevant MaRisk areas and incorporating them into the audit universe. Audit Methodology: Development of structured audit approaches tailored to MaRisk topics that promote both the effectiveness and efficiency of the audit as well as acceptance of the results. Audit Tools and Resource Planning: Advisory support in selecting and implementing appropriate tools and the efficient allocation of audit resources for MaRisk topics.

Structured, current, and accessible documentation is a fundamental pillar of MaRisk compliance and is scrutinised intensively during supervisory reviews. At the same time, the creation and maintenance of documentation ties up considerable resources. ADVISORI supports you in developing an efficient documentation management system that meets regulatory requirements while minimising the associated effort. Strategic Documentation Concept: Documentation Architecture: Development of a structured documentation hierarchy ranging from overarching frameworks through area-specific policies to detailed work instructions, enabling consistent, redundancy-free documentation. Risk-Based Detailing: Support in determining the appropriate granularity and level of detail for documentation, which is more comprehensive in critical areas and can be kept leaner for less risk-relevant topics. Life-Cycle Management: Establishment of a systematic lifecycle approach for documents, from conception through creation, approval, and regular review to controlled retirement. Regulatory Mapping: Development of a transparent mapping between MaRisk requirements and your documentation that ensures completeness and identifies gaps or redundancies. Efficient Documentation Processes: Streamlined Authoring Process: Optimisation of the creation and update process for documents with clear responsibilities, timelines, and quality assurance mechanisms.

Continuous improvement is a fundamental principle of sustainable MaRisk compliance management. Given evolving regulatory requirements, changing business models, and increasing efficiency expectations, the systematic further development of your compliance structures and processes is critical to long-term success. ADVISORI supports you in establishing a structured continuous improvement approach for your MaRisk compliance. Strategic Framework for Continuous Improvement: Compliance Excellence Vision: Development of a clear, motivating target picture for your MaRisk compliance that goes beyond mere rule conformity and encompasses efficiency, effectiveness, and value contribution. Maturity Model Approach: Implementation of a maturity model for various dimensions of your MaRisk compliance that assesses the current state, defines development targets, and makes progress measurable. Innovation Framework: Establishment of a structured framework for the continuous identification, evaluation, and implementation of effective approaches in compliance management. Resource Roadmap: Development of a long-term plan for the allocation of resources to improvement initiatives that takes into account both quick wins and strategic transformations.

Sustainable MaRisk compliance requires more than the point-in-time fulfilment of regulatory requirements. It is based on a comprehensive approach that integrates technical, organisational, and cultural aspects and positions the compliance function as a strategic partner to the business. Drawing on many years of experience, ADVISORI has identified the critical success factors for sustainable MaRisk compliance and supports you in implementing them in a targeted manner. Strategic Alignment and Governance: Business Alignment: Support in strategically aligning the compliance function with business objectives, developing it from a pure control function into an enabler of sustainable business success. Clear Governance: Design of transparent governance structures with unambiguous responsibilities, decision-making pathways, and accountability across all three lines of defence. Management Commitment: Promotion of active commitment at leadership level that goes beyond verbal declarations and manifests in concrete action, resource allocation, and leading by example. Integrated Management Approach: Development of a comprehensive approach that interlinks compliance management with other governance areas such as risk management and internal control.