On several occasions the Bank of Italy has recalled the need for a stronger presence of Internal control functions on crucial transparency and fairness issues in the customer relationships. The tools and the modus operandi of Compliance are rapidly evolving. Within the internal control system, Compliance must work toward minimizing legal and reputational risks. The various stages of the function’s activities – from ex ante to ex post – must be appropriately defined in proportion to the complexity of the company and exogenous factors. The design of the controls must be customized, adapted over time, declined by priority and fully aware of the evolution of the business model and customers.
