The law requires certain financial institutions to conduct a systematic integrity risk analysis (SIRA). The purpose is to identify the inherent integrity risks in order to take appropriate measures to control these risks.
Regulators DNB and AFM pay special attention to the SIRA. This training helps you to successfully conduct a SIRA and thus meet the requirements of the regulators.
Tailored to your work environment
In practice, the process of conducting a systematic integrity risk analysis is often similar. However, the context in which you conduct a SIRA differs from organisation to organisation. The background of the people involved is also diverse. During this training we take these differences into account as much as possible. No ‘one size fits all’ approach, but sufficient attention for your specific knowledge and experience and the environment in which you work.
Benefits of The Ministry
Only learn what is relevant
We want you to learn what is relevant to you. This means that you do not have to study theory that you already know or that is not applicable to your organisation. However, we do offer you all the information you need to conduct a good SIRA.
Focus on a practical assignment
To make this training as practical as possible, you will focus on conducting a SIRA yourself. We will start the course with a short kick-off. After you have gone through the theory in our online learning environment, you will carry out an assignment in your own organisation. After handing in the assignment, you will receive individual feedback from the trainer. Then, we discuss the pitfalls and best practices with each other during a plenary meeting. Throughout the training you will be guided by an experienced compliance specialist from Projective Group
A central element of the training is conducting a SIRA in your own context.
Target audience
Banks, insurers, pension funds and trust offices are all obliged to perform a SIRA. However, a SIRA is also a good way for other financial organisations to gain insight into integrity risks and their control. This training has therefore been developed for everyone from the first, second or third line who is directly involved in performing a SIRA and wants to learn how to do this successfully.
This training is available in-company, to attend with an entire team or department at once.
Prior knowledge
This is a training at HBO (higher vocational education) level. As a starting point, we assume that you have a good idea of the integrity risks that a financial organisation can face and how these can be managed.
If the group consists of a mix of English and Dutch speaking participants, English will be spoken during the plenary meetings. The theory is available in Dutch and English. You can decide whether you want to do the assignments in Dutch or English.
Objective
During this course you learn to:
Formulate a working method for conducting a SIRA;
Provide an outline of your organisation with the right quantitative and qualitative elements;
Identify integrity risk scenarios for your organisation and analyse them using the DNB template;
Visualise the results of the integrity risk analysis in a heatmap as a basis for discussion with the management team.
The knowledge you need for this can be found in the theory part of this course.
Structure
This course consists of the following components:
1. Kick-off meeting via Teams to introduce the training;
2. Self-study via the online learning environment;
3. Carrying out the assignment in your own organisation;
4. Individual feedback on your assignment;
5. Plenary meeting to discuss elaborations, best practices, pitfalls, etc.;
6. If necessary: refining the details of the assignment.
Theory
Integrity
Steps SIRA
Practical tips SIRA
Risks and control measures
Analysis of control
Context of the SIRA – ANNEX
Sound business practice
From norm to control
Conduct investigations
Assessment
Central to the course is doing a SIRA in your own context. The elaboration of this is the testing element of this course. The resit consists of improving previous assignments based on the plenary session, the substantiation of the assessment and the tips provided by the trainer.
Certificate
You will receive a certificate if you have completed the assignment to a satisfactory standard.
Wwft risk assessment as part of the SIRA
The SIRA methodology used in this course is also applicable to the mandatory risk assessment under the Wwft. A Wwft risk assessment is limited to the risks of money laundering, financing of terrorism and circumvention of sanction regulations, whereas the SIRA covers all forms of integrity risks. Other forms of client integrity risks – such as fraud or tax evasion – are also part of Wwft policies and procedures in practice. The SIRA provides a good basis for this.
The compliance specialists of Projective Group that lecture this course therefore advise to conduct the Wwft risk assessment as part of the SIRA. And not only from an efficiency point of view. Also because when performing the SIRA you create an organisation outline and risk profile (including risk appetite). These are guiding principles for carrying out the risk assessments and for qualifying the results. In addition, they ensure that risks are focused on the nature and size of your own organisation.
Confidentiality
The assignments in this course are carried out in your own context and based on your organisation’s issues and set-up. This may involve confidential information.
The starting point is that only the trainer of the course will see your assignments. All trainers have signed a confidentiality agreement.
You can choose to share your information with your fellow students. This will benefit the discussion in the training. It is up to you to decide if and how you want to do that: concretely, in general terms or anonymously.
Study load
This course takes about a month in total. The study load varies per student, depending on relevant prior knowledge and experience.
Kick-off meeting: 1 hour
Self-study: 1-3 hours
Carrying out the assignment: 16 hours
Discussion meeting: 8 hours
Why this SIRA training?
Learn to do a good SIRA independently
Meet the requirements of AFM and DNB
Developed by compliance specialists from Projective Group
Starting dates
The SIRA training is available in-company, to attend with an entire team or department at once. We are happy to tailor the training to your organisation and adjust the content to your policies and procedures. Please contact us for more information about starting dates and customisation.
We use technologies such as cookies to store and/or access device information. We do this to enhance the browsing experience and to show (non-)personalized ads. By giving consent to these technologies we may process data such as browsing behavior or unique IDs on this site. If you do not give consent or withdraw your consent, this may negatively impact certain functions and features.
Functional
Always active
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service expressly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Preferences
The technical storage or access is necessary for the legitimate purpose of storing preferences not requested by the subscriber or user.
Statistics
De technische opslag of toegang die uitsluitend voor statistische doeleinden wordt gebruikt.The technical storage or access used solely for anonymous statistical purposes. Without a subpoena, voluntary compliance by your Internet Service Provider, or additional data from a third party, information stored or retrieved solely for this purpose usually cannot be used to identify you.
Marketing
The technical storage or access is necessary to create user profiles for sending advertising or to track the user on a site or across different sites for similar marketing purposes.