Regulatory and compliance risk continues to evolve in both scope and complexity, requiring financial institutions to move beyond reactive approaches and toward more structured, forward-looking programs. As expectations shift and scrutiny intensifies, compliance functions are being asked not only to manage risk, but to demonstrate how effectively they govern and adapt.

Building resilient, future-ready compliance programs requires a coordinated approach across governance, risk identification, testing, and remediation—supported by enabling technologies and integrated operating models. The eight areas below highlight how institutions are strengthening compliance infrastructure and meeting evolving regulatory expectations.

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How financial institutions can build resilient, future-ready compliance programs

  1. Compliance program management
    A mature compliance program is the foundation of everything else. Leading institutions are assessing compliance programs, identifying gaps against regulatory expectations, and strengthening frameworks, governance structures, and policies that underpin effective risk management. This includes organizational resourcing assessments, compliance technology and systems reviews, Law, Rule, and Regulation (LRR) and obligation mapping—giving institutions a clear picture of where they stand and a credible path forward.
  2. Risk and control self-assessments (RCSAs)
    Effective RCSAs are more than a compliance checkbox. Leading practices standardize the process of identifying and evaluating risks, assessing control effectiveness, and documenting gaps while developing remediation roadmaps. This includes RCSA framework and methodology reviews, business process mapping, and the ability to scale resources in response to accelerated timelines or evolving demands.
  3. Compliance testing
    Independent, evidence-based compliance testing is essential for validating control effectiveness and identifying high-risk areas before regulators do. As regulators shift their focus from process compliance towards measurable risk reduction, the bar for what “good” testing looks like has risen. Leading compliance programs implement targeted compliance testing including control testing execution, transactional testing, and outcomes-based testing with rigorous QA/QC and a scalable delivery model. Testing is increasingly tied directly to the enterprise’s risk posture and risk appetite, ensuring resources are deployed where they matter most and that results are clear and defensible.
  4. Regulatory relations center of excellence (CoE)
    Exam readiness and regulator engagement are disciplines in their own right. Leading institutions are establishing regulatory relations CoEs that standardize regulatory responses, define clear governance and communication protocols, and enable timely, accurate regulator engagement. This includes support for regulatory interactions and inquiries, exam readiness, exam management, and executive board and regulatory reporting, as well as independent testing and remediation support for Matters Requiring Attention (MRAs), Matters Requiring Immediate Attention (MRIAs), consent orders, and supervisory commitments.
  5. Regulatory change management
    Keeping pace with regulatory change requires more than monitoring—it requires the capability to translate regulatory shifts into operating model adjustments before gaps become findings. Recent changes across the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve, and Consumer Financial Protection Bureau (CFPB)—including evolving supervisory expectations and enforcement priorities—signal not reduced risk, but redirected risk, requiring compliance programs to continuously adapt or remain exposed. Leading programs are adopting agile, governance-led approaches to regulatory change by aligning risk, delivery, and cross-functional teams to drive efficient, scalable outcomes. This includes regulatory change assessments, remediation consolidation, technology implementation and dependencies (including ERM and AML system implementations), and structured reporting to support sustained compliance.
  6. Consumer protection and fairness
    Institutions must consistently demonstrate that they treat customers fairly across their products, services, and customer interactions. Leading institutions are enhancing consumer protection capabilities through compliance readiness assessments, product lifecycle reviews, consumer regulatory protection reviews across the full regulatory A-to-Z scope, fair banking and fair lending program reviews, and disputes, complaints, and fraud management.
  7. Issues management
    In a regulatory environment that increasingly demands evidence of measurable risk reduction, unresolved or poorly tracked issues create regulatory and reputational exposure, and a weak issues management program is itself a finding risk. Effective issues management programs establish clear governance, quality control, and consistent remediation across all lines of defense. This includes structured issue identification and assessment, monitoring and remediation management, reporting, oversight, and advisory—and AI-enabled approaches to accelerate issue management and address large remediation backlogs.
  8. Digital banking compliance
    As institutions expand digital banking capabilities and deploy AI across customer-facing and risk management functions, compliance must remain foundational. Regulators across the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), and Financial Stability Oversight Council (FSOC) have identified AI governance, model explainability, data lineage, and auditability as key examination priorities. Institutions that accelerate AI adoption without corresponding governance frameworks carry material regulatory exposure. Leading institutions are embedding compliance into digital transformation by integrating regulatory requirements into product design, deployment, and governance frameworks. This includes strengthening LRR mapping, aligning risk and control inventories, and ensuring that innovation and oversight evolve together.

Together, these eight areas reflect how leading institutions are strengthening compliance infrastructure to stay ahead of evolving regulatory expectations.

Meeting the regulatory compliance challenge head on

Across the industry, several principles consistently separate high-performing compliance programs from those that struggle:

  • Governance before tools: Technology accelerates compliance only when supported by clear governance, defined roles, and documented obligations. Institutions that invest in tools before governance often find themselves with expensive infrastructure and persistent risk and compliance gaps.
  • Evidence-based testing: Regulators increasingly expect institutions to demonstrate control effectiveness through rigorous, defensible testing across multiple lines of defense—not just attestations. A testing program tied to risk appetite and supported by independent QA/QC is a meaningful differentiator in regulator exam outcomes.
  • Integrated change management: Regulatory change that is tracked in isolation—disconnected from business lines, technology teams, and product owners—creates implementation gaps that regulators will find before you do. Institutions that treat regulatory change as a cross-functional discipline are better positioned to implement requirements accurately, on time, and with documentation that holds up under scrutiny.
  • Proactive exam engagement: The institutions that fare best in regulatory exams are those that engage proactively with regulators and treat exam preparation as continuous discipline rather than a pre-exam sprint. Implementing regulatory relations CoE with clear governance, pre-exam preparation protocols, and structured communication practices reduces exam risk meaningfully.

These principles reflect observable differentiators in how institutions perform under regulatory scrutiny.


The compliance imperative: Building for what’s next

The regulatory environment will continue to evolve, and institutions best positioned to navigate it are those that build compliance programs with the governance, infrastructure, and testing rigor to stay ahead of risk and scrutiny, particularly as AI-driven processes introduce new regulatory expectations. The opportunity for compliance leaders is to shift from reactive oversight to proactive, strategic enablement of the business.

Institutions that take this approach position compliance as a strategic enabler rather than a reactive function. To start transforming your institution’s approach to regulatory and compliance risk, contact CrossCountry Consulting

Connect with an expert

Mike Pugliese

Banking & Capital Markets and Business Transformation

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Contributing authors

Sarah Calenda

Haylee Castora