SAM introduces massively complex new legislation which at first glance provides enormous amounts of additional work for insurers’ compliance departments.
But given the concepts behind SAM, is it really a compliance exercise or is it a business and risk management exercise?
Ultimately, insurers will need to decide how they are going to meet the SAM objectives and principles, codify this in their own documents and then comply with those.
The role of compliance here is two-fold:
- Ensure that the chosen approach to complying with SAM will in fact achieve compliance
- Ensuring the company’s practice is compliant with their own chosen approach
I gave a SAM update session to compliance officers recently. There is some of the standard material in there, but with a slant more towards what compliance officers need to know about SAM.