ZYC-COM-001 Compliance Oversight Policy
Purpose
To define how Zeyro identifies, monitors, and reports compliance risk under the UK MiFID framework and Section 21 financial-promotion regime. This policy ensures compliance activities are independent, risk-based, and proportionate to our scale and business model.
Scope
Applies to all Zeyro functions subject to FCA supervision, including:
Financial-promotion approvals (cryptoasset and OFR)
Facilities-service arranging activity
Governance, AML, and operational controls
Policy Statement
Zeyro maintains a single, integrated compliance framework overseen by the MLRO (SMF 16 & 17). Compliance oversight is continuous, data-driven, and aligned with the firm’s Business-Wide Risk Assessment (BWRA). The Board retains ultimate accountability for compliance, with operational monitoring delegated to the MLRO.
Oversight Framework
1. Compliance Planning
The MLRO prepares an annual Compliance Monitoring Plan (CMP) based on the BWRA and known regulatory priorities.
The plan defines the scope, frequency, and methodology of monitoring for each business line.
2. Monitoring & Testing
Monitoring includes:
Desk-based reviews of approvals, onboarding files, and risk scoring.
Periodic deep-dives into high-risk areas identified in the BWRA.
Control testing of DotFile, Microsoft 365, and Atlassian-Suite workflows.
Follow-up tracking in Jira Service Management until all actions are closed.
Results are documented in the CMP workspace within Confluence.
3. Issue Escalation & Reporting
Material breaches or control failures are logged in the Breach Register and reported to the Board within 10 business days.
The MLRO produces a quarterly Compliance Report summarising findings, trends, and remedial actions.
Urgent issues are escalated immediately to the Board Chair or Non-Executive Director (Giles Swan).
4. Continuous Improvement
Monitoring outcomes inform updates to:
the BWRA;
the CMP; and
relevant policies and procedures.
Controls risk: ensures feedback from monitoring directly improves governance and control effectiveness.
Roles and Responsibilities (RACI)
Role
Responsibility
Accountability
Consulted / Informed
Operational Staff
Operate controls; cooperate with reviews; implement actions.
MLRO
MLRO / Board
MLRO (SMF 16 & 17)
Design CMP; conduct monitoring; report breaches; maintain registers; update policies.
Board
Operational staff
Board
Approve CMP and policies; review quarterly reports; ensure adequate resources.
—
MLRO
Non-Executive Director (Giles Swan)
Provide independent challenge and oversight of compliance reporting.
Board
MLRO
Controls risk: assigns clear lines of responsibility and escalation consistent with FCA SYSC 6 and SMCR principles.
Review
This policy and the Compliance Monitoring Plan are reviewed annually or earlier if there are regulatory or structural changes.
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