While banking organizations sometimes outsource compliance testing or other compliance function tasks, the organization itself remains accountable and must exercise appropriate oversight. The "war for talent" We've heard industry leaders refer to their compliance recruitment process as a "war for talent." Running an effective enterprise-wide compliance-risk management program requires more than  BIS Review 42/2006  3  policies, procedures, and management information systems.
Decisions are made by senior management on the basis of advice from their staff. Consequently, talent is required at all levels. In assessing the risk management of individual organizations, we have noted the importance of staff who have experience and expertise consistent with the scope and complexity of an organization's business activities.