Compliance function in Italian banks: organizational issues

Purpose - The authors' paper aims to examine the organizational issues that come from the recent establishment of the compliance function in Italian banks. Design/methodology/approach - The authors' paper takes as a starting point the Bank of Italy's regulations and the existing literature on compliance, in order to create a theoretical model of an efficient internal control system. Findings - For each organizational structure of compliance, the authors' paper describes strengths and weakness. It also outlines the scopes of compliance and internal audit in order to avoid overlaps. Having regard to the similarities between operational risk and compliance risk, the study identifies cooperation areas so as to achieve synergies, in terms of costs, and a better operational efficiency. Research limitations/implications - The authors' paper focuses mainly on the relationship between compliance, on one side, and internal audit and risk management on the other. It focuses also on the positioning of compliance within the internal control system, as it has been regulated by the Italian disposals. Further research could concern the relationship with other functions and the regulations of other countries. Practical implications - The authors' paper identifies cooperation forms between the internal control system functions. This is the way to suggest organizational solutions able to improve banking efficiency. Originality/value - This subject has not been analyzed in depth to date. This article attempts to obtain an identification of the roles and responsibilities of the main functions involved in the internal controls system, in order to define organizational models characterized by complementarity of interventions and thus oriented towards the objectives of effectiveness and efficiency.