What To Consider When Drafting And Amending Internal Rules?

Internal rules are important throughout the life-cycle of a financial institution. Appropriate internal rules play a key role in ensuring that the financial institution's operations comply with legal acts and thereby in mitigating the possibility that a compliance risk materialises. Therefore, it is necessary to pay sufficient attention to drafting and amending the internal rules.

Process based internal rules.

Internal rules should be drafted with a sufficient level of detail. Whereas it is important that the internal rules are not merely principle-based, simply listing the financial institution's various obligations under legal acts. Listing obligations would leave excessive room for interpretation in terms of what should be done to comply with a particular obligation. This in turn gives leeway to the interpretation that the performance of such obligation of the financial institution would have required additional activities, therefore, the financial