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Compliance Officer Requirements

This article received quite a bit of attention from the market. We respond to two of the questions received from from readers.

I just recently received the Moonstone Monitor for today and have a comment on the article – ‘Requirements for Compliance Officers.’ The article states:

“Please note that the list of qualifications has not yet been finalized and therefore has not yet been published as Annexure 2 of Board Notice 127 of 2010. Nothing has happened since September 2010.”

But what of Board Notice 136 of 2012? The list is very limited which in my mind would mean we would have to apply to have our qualifications recognised if appointed after 10 September 2010. Is this correct? CH.

Dear C

Our legal department responded as follows to your enquiry.

BN. 136 of 2012 does indeed contain the most recent list of recognised CO qualifications.

If a particular qualification does not appear on the list, one can apply for its inclusion. Such qualification must, however, comply with the 3 Subject Rule. If not, it will not be considered for inclusion and, obviously, as a recognised qualification.

This Board Notice was published together with BN 135 which contained a number of errors, and is currently being rectified.

We are also aware of some CO qualifications which we applied for, and which were approved, but are not yet included in BN 136. It is possibly best to wait for the new BNs to be published, or make enquiries to the FSB, prior to spending a substantial amount on applying for recognition of a qualification already approved.

I was the internal compliance officer for my brokerage. We made use of an external compliance provider for a period, but I have since taken over this responsibility again. In which of the categories, listed in your article, do I fall?

The Board Notice does not specifically refer to this. We are of the view that the DOFA principle (date of first appointment) will also apply here. In other words, your date of appointment as a compliance officer will determine which requirements apply to you.

Please click here to download the article setting out the various time frames and its application to CO requirements.

In closing: if you are a qualified compliance officer, looking for a career change (or opportunity) with the leading independent compliance provider in the country, please forward your CV to

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