Mar 22 / Evdokia Pitsillidou

The Annual MiFID Compliance Report

about the author

Evdokia Pitsillidou

Director of Risk & Compliance at SALVUS Funds

Evdokia, a partner at SALVUS Funds, is actively advising and working on all matters related to licensing, regulatory compliance, and internal audit for investment firms, funds, Electronic Money Institutions (EMI) & Crypto-Asset Services Providers (CASP).

  • Member of the Global Institute of Internal Auditors (IIA)
  • Member of the Cyprus Investment Funds Association (CIFA)
  • Certified Actuarial Analyst (CAA)
  • CySEC Advanced Certified Person
  • CySEC certified Anti-Money Laundering Compliance Officer (AMLCO)

Compliance professionals working at Investment Firms, are well aware that the Annual Compliance Report is a mandatory reporting obligation and one of the most important reports to the Board members of regulated entities licensed to offer investment services. It serves as an overview of each firm's adherence to the requirements outlined in the Markets in Financial Instruments Directive (MiFID).

In this blog post, IforPE instructor Evdokia Pitsillidou delves into the analysis of Circular C553 which is dedicated to providing guidance on certain aspects of the compliance function requirements. As part of this discussion, the blog introduces an inclusive course titled "How to Prepare the MiFID Compliance Report in 2024" available on the IforPE platform.

Towards the conclusion of the post, we provide details about the insights gained from participating in the course and how they can assist in crafting the corresponding report effectively.


CySEC’s Circular C553

The Cyprus Securities and Exchange Commission (CySEC) published Circular C553 with which it provided direction on how to apply certain aspects of the compliance function requirements. Through this Circular 12 Guidelines are introduced as presented below:

Compliance Function responsibilities

     - Guideline 1: Compliance risk assessment

     - Guideline 2: Monitoring obligations of the compliance function

     - Guideline 3: Reporting obligations of the compliance function

     - Guideline 4: Advisory and assistance obligations of the compliance function

Compliance Function organisational requirements

     - Guideline 5: Effectiveness of the compliance function

     - Guideline 6: Skills, knowledge, expertise and authority of the compliance function

     - Guideline 7: Permanence of the compliance function

     - Guideline 8: Independence of the compliance function
     - Guideline 9: Proportionality with regard to the effectiveness of the compliance function

     - Guideline 10: Combining the compliance function with other internal control functions

     - Guideline 11: Outsourcing of the compliance function

Competent authority review of the Compliance Function

      - Guideline 12: Review of the compliance function by the competent authorities

The Guideline that focuses on the reporting obligations of the Company in regard to compliance matters, is considered to be Guideline 3. Through this guideline, the regulator reminds the obliged under MiFID entities of their responsibility to submit on an annual basis the Compliance Report. It also clarifies that this is a responsibility of every company’s Compliance Function and shall include a thorough review of all business units participating in the provision of investment and ancillary services. 

As part of the Compliance Monitoring Program (CMP), the Compliance Officer shall present the major findings from the review of the firm’s policies and procedures, along with the risks arisen from its compliance monitoring activities. To that end, actions to be taken to mitigate the findings shall be included within the review of each department.

What is the MiFID Compliance Report course and what does it include?

The MiFID Compliance Report course, developed by SALVUS Funds and is delivered by their Risk & Compliance Director, Evdokia Pitsillidou, aims to assist Compliance Officers and members of the Compliance Department in creating comprehensive and well-organized reports. It further examines Circular C553 guidelines on specific aspects of compliance function requirements. Additionally, it serves as a valuable resource for Board of Directors members, aiding them in reviewing and approving the report.

By participating in this course, individuals gain access to the guidelines for a structured report, to assessment areas to be covered, and to practical compliance recommendations for report preparation, review, and approval. The course content draws from the extensive experience of the SALVUS Regulatory Compliance team in crafting compliance reports for entities of various business models.

The Syllabus of the MiFID Compliance Report course includes:

  • Compliance Function
    - Responsibilities
    - Effectiveness, permanence & independence
    - Organisational requirements
    - Monitoring obligations
    - Compliance Function: Q&As
  • CySEC Circular C553 - Guidelines on certain aspects of the compliance function requirements
    - CySEC Circular C553
    - Compliance Function responsibilities
    - Compliance Function organisational requirements
    - Competent authority review of the Compliance Function
  • Introduction on how to prepare the Annual MiFID Report
    - Obligation, Purpose & Significance
    - Timeline & Reference period
    - Submission to the Board of Directors
    - Board of Directors minutes
    - Submission to CySEC
    - Contents of the Report
  • The Annual MiFID Report; Executive Summary
    - Characteristics

    - Structure
    - Findings & Rectifications from previous year
    - Findings & Recommendations for this year
  • The Annual MiFID Report; Company Information, Legal Framework & the Business Divisions
    - The Company
    - Legal Framework
    - Business Divisions
  • The Annual MiFID Report; Compliance Function Inspections, desk-based and onsite
    - Policies and Procedures
    - Organizational Requirements & Operating Conditions
    - Client Account Opening & Closing
    - Back-Office Department
    - AML Department
    - Accounting & Finance
    - Provision of Services
    - Business Development & Customer Support
    - Information Technology
  • The Annual MiFID Report; CySEC Communication & Reporting tips
    - Correspondence with CySEC
    - Other competent authorities
    - Reporting tips

The material of the MiFID Compliance Report course is provided in both PDF slides and online video recordings, designed specifically for self-study learning. Learners who register for this course are provided with the flexibility to learn wherever, whenever.
In addition, learners can test their acquired knowledge upon completion of the course by undertaking a set of test questions based on the material covered.

The completion of this course counts towards the Continuous Professional Development (CPD) annual requirements of professionals, holders of the CySEC Advanced and Basic certifications.
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