What can serve as evidence of a bank's compliance culture?

Thorough documentation of compliance activities serves as a strong indicator of a bank's compliance culture because it demonstrates the organization's commitment to adhering to regulatory standards and internal policies. This documentation provides a clear and traceable record of compliance processes, including risk assessments, training programs, audits, and corrective actions taken when necessary.

By maintaining detailed records, a bank can show regulators, employees, and stakeholders that it prioritizes compliance, actively manages risks, and is dedicated to fostering a culture of ethical behavior. Consistent and organized documentation reflects a proactive approach to compliance that can lead to improved overall governance and accountability within the institution.

In contrast, disorganized operational processes and frequent changes to management policies may signal instability or a lack of focus on compliance, undermining the trust of stakeholders and regulators. Regular employee feedback surveys, while valuable for assessing the compliance culture, are not as definitive on their own as documentation that directly showcases compliance activities and practices. Therefore, documentation stands out as the most compelling evidence of a robust compliance culture.