Board Compliance Reporting Outline
This outline defines the standing agenda for compliance reports to the Board or designated Committee. Reports are prepared by the CECO (Fractional CCO) with input from the MLRO, Legal, and operational leads per the RACI Matrix.
Reporting cadence
Monthly — Management summary
5–8 page executive brief to CEO and management committee. Highlights material movements, open actions, and regulator touchpoints. Escalates items requiring Board attention.
Quarterly — Board / Committee pack
Full compliance report (15–25 pages including annexes). Standing agenda below. Presented by CECO with MLRO input on AML/CTF sections.
Ad hoc — Material incident
Within 5 business days of classification. 2–4 page flash report covering facts, impact, root cause, remediation, and regulatory notification status.
Annual — Program effectiveness
Comprehensive review: risk assessment results, independent review findings, charter reaffirmation, and next-year work plan.
Quarterly board report — standing agenda
1. Executive summary
- Overall compliance posture rating (Green / Amber / Red) with one-paragraph rationale
- Top 3 conduct and regulatory risks for the quarter
- Material incidents and status of remediation
- Regulatory engagement summary (SPK, MASAK, EU competent authority)
- Actions requiring Board decision or notation
2. E&C program status
- Program KPI dashboard: speak-up reports received, investigations opened/closed, average cycle time, training completion by role
- Policy updates adopted in the period
- Conduct risk assessment updates or trigger events
- Third-party due diligence coverage (% of critical vendors current)
- Open investigation summary (anonymised; material cases flagged)
3. AML / CTF & financial crime (MLRO section)
- AML risk assessment status and key risk drivers
- STR / SAR filings: count, typologies, and feedback from MASAK or other FIU
- Sanctions screening metrics: alerts, true positives, system performance
- KYC onboarding volumes, EDD triggers, and periodic review backlog
- Transaction monitoring alert volumes and disposition rates
4. Regulatory & licensing
- SPK / KVHS licensing milestones and outstanding conditions
- Regulatory correspondence and examination activity
- MiCA readiness status (if applicable): authorisation timeline, governance gaps, reserve attestation
- Cross-border entity mapping updates
- Regulatory change horizon — upcoming rules affecting operations
5. Crypto-specific conduct & operations
- Token listing decisions — volume, conflict disclosures, rejected applications
- Market conduct monitoring: alerts, confirmed issues, enforcement actions
- Proprietary / treasury trading activity summary and conflict controls
- Custody and customer asset reconciliation status
- DeFi / on-chain exposure and counterparty risk updates
- Marketing and promotion compliance review
6. Technology & RegTech
- Compliance system uptime and incident log
- Transaction monitoring / KYC platform changes or upgrades
- On-chain analytics coverage and gaps
- Data privacy and information security incidents with compliance impact
- RegTech roadmap progress (if Package F engaged)
7. Third-party & outsourcing
- Critical vendor status: custodians, market makers, KYC providers, cloud infrastructure
- New onboarding and terminated relationships
- Outsourcing risk assessment updates
- Contractual compliance obligations — breaches or renegotiations
8. Internal audit & external findings
- Open audit findings by severity and age
- Remediation progress vs. agreed timelines
- Repeat findings and root cause themes
- External legal or compliance review outcomes
9. Forward look & resource needs
- Next-quarter priorities and planned policy/training initiatives
- Resource and budget requests for Program enhancement
- Emerging risks from business expansion, new products, or jurisdictions
- Board actions requested (approvals, charter updates, risk appetite decisions)
Annexes (quarterly)
- Annex A: Detailed KPI tables and trend charts (6-quarter lookback)
- Annex B: Regulatory correspondence log
- Annex C: Open actions register with owners and due dates
- Annex D: Jurisdiction matrix update (if changed)
- Annex E: Training completion by department
Distribution & confidentiality
- Board / Committee members, CEO, CECO, MLRO, General Counsel
- Restricted circulation — not for external sharing without Board approval
- Retained for minimum 5 years (or per local regulatory record-keeping requirements)