Compliance and risk officer

This document explains the requirements for end-point assessment (EPA) for the compliance and risk officer apprenticeship. End-point assessment organisations (EPAOs) must follow this when designing and delivering the EPA.

Compliance and risk officer apprentices, their employers and training providers should read this document.

A full-time compliance and risk officer apprentice typically spends 15 months on-programme (this means in training before the gateway). The apprentice must spend at least 12 months on-programme and complete the required amount of off-the-job training in line with the apprenticeship funding rules.

The apprentice must complete their training and meet the gateway requirements before starting their EPA. The EPA will assess occupational competence.

An approved EPAO must conduct the EPA for this apprenticeship. Employers must select an approved EPAO from the register of end-point assessment organisations (RoEPAO).

This EPA has 2 assessment methods.

The grades available for each assessment method are below.

Assessment method 1 - interview underpinned by a portfolio of evidence:

• fail

• pass

• distinction

Assessment method 2 - written project report with presentation and questions:

• fail

• pass

• distinction

The result from each assessment method is combined to decide the overall apprenticeship grade. The following grades are available for the apprenticeship:

• fail

• pass

• merit

• distinction

The EPA is taken in the EPA period. The EPA period starts when the EPAO confirms the gateway requirements have been met and is typically 5 months.

The EPAO should confirm the gateway requirements have been met and the EPA should start as quickly as possible.

The apprentice’s employer must be content that the apprentice is occupationally competent. That is, they are deemed to be working at or above the level set out in the apprenticeship standard and ready to undertake the EPA. The employer may take advice from the apprentice's training provider, but the employer must make the decision. The apprentice will then enter the gateway.

The apprentice must meet the gateway requirements before starting their EPA.

They must:

• confirm they are ready to take the EPA
• have achieved English and mathematics qualifications in line with the apprenticeship funding rules
• have passed one of the following qualifications:

ICA International Advanced Certificate in Governance, Risk and Compliance

ICA Advanced Certificate in Managing Fraud

ICA International Advanced Certificate in Anti Money Laundering

ICA Advanced Certificate in Practical Customer Due Diligence

ICA Advanced Certificate in Business Compliance

ICA Certificate in Compliance

ICA Certificate in Anti Money Laundering

ICA Certificate in Financial Crime Prevention

ICA Specialist Certificate in Financial Crime Risk and New Technology

ICA Specialist Certificate in Money Laundering Risk in Betting and Gaming

ICA Specialist Certificate in Conduct Risk

CISI Award in Combatting Financial Crime

CISI Award in Global Financial Compliance

CISI Award in Risk in Financial Services

CICM Level 3 Diploma in Credit and Collections

• submit a portfolio of evidence for the interview underpinned by a portfolio of evidence

• submit a project title and scope for the written project report with presentation and questions

Portfolio of evidence requirements

The apprentice must compile a portfolio of evidence during the on-programme period of the apprenticeship. The portfolio should only contain evidence related to the KSBs (Knowledge, Skills and Behaviours) that will be assessed by the interview assessment method. Typically, it will contain 10 discrete pieces of evidence and must be mapped against the KSBs for the interview assessment method. Evidence may be used to demonstrate more than one KSB; a qualitative approach is suggested as opposed to a quantitative one.

Evidence sources may include:

• workplace documentation and records, for example:
• workplace policies and procedures
• witness statements
• annotated photographs
• video clips (maximum total duration 8 minutes); the apprentice must be in view and identifiable.

This is not a definitive list and other evidence sources can also be included.

The portfolio of evidence should not include reflective accounts or any methods of self-assessment. Any employer contributions should focus on direct observation of performance (for example, witness statements) rather than opinions. The evidence provided should be valid and attributable to the apprentice. The portfolio of evidence should include a statement from the employer and apprentice confirming its authenticity.

The EPAO should not assess the portfolio of evidence directly as it underpins the interview. The independent assessor should review the portfolio of evidence to prepare questions for the interview. They are not required to provide feedback after this review.

Written project report requirements

The project title and scope will be agreed between the employer and EPAO at gateway to ensure sufficient coverage of the assigned KSBs.

Gateway evidence must be submitted to the EPAO, along with any organisation specific policies and procedures requested by the EPAO.

Assessment methods 1 and 2 can be delivered in any order or concurrently, and the result of one assessment method does not need to be known before starting the next. However, the assessment components in assessment method 2 cannot be delivered in any order. The written project report must be completed before the presentation and questions can take place.

The rationale for the order of the components in assessment method 2 is that the presentation will enable the apprentice to present the findings of their written project report. Additionally, it enables the assessor to assess any KSBs that may not have been fully captured in the report. Furthermore, the presentation provides the assessor with an the opportunity to verify that the report is indeed the work of the apprentice.

Consideration can be given to which KSBs are best evidenced by the diffent components of assessment method 2. Whilst all KSBs attached to this assessment method must be demonstrated, it is not necessary to duplicate demonstration in both the written project report and the presentation.

Overview

In the interview, an independent assessor will ask the apprentice questions. It gives the apprentice the opportunity to demonstrate the KSBs mapped to this assessment method.

Rationale

The rationale for this assessment method is that:

• it allows scope for the apprentice to demonstrate the depth and breadth of their understanding of the KSBs
• it allows the independent assessor to consider the context and sector that the apprentice operates in, giving flexibility to ensure that all the KSBs can be assessed appropriately.

reduces the assessment burden on the apprentice

Delivery

The interview must be structured to give the apprentice the opportunity to demonstrate the KSBs mapped to this assessment method to the highest available grade.

An independent assessor must conduct and assess the interview.

The purpose of the independent assessor’s questions will be to assess the apprentice’s competence against the following themes:

• Delivering services
• Systems and processes
• IT and digital
• Green finance
• Analysis and problem solving
• Customers and products.

The EPAO must give an apprentice 3 weeks' notice of the interview.

The independent assessor must have at least 2 weeks to review the supporting documentation and generate appropriate questions for the interview. The independent assessor must use questions from the EPAO's question bank or create their own questions in line with the EPAO's training.

The apprentice must have access to their portfolio of evidence during the interview.

The apprentice can refer to and illustrate their answers with evidence from their portfolio of evidence however, the portfolio of evidence is not directly assessed.

The interview must last for 60 minutes. The independent assessor can increase the time of the interview by up to 10%. This time is to allow the apprentice to respond to a question if necessary.

The independent assessor must ask at least 6 questions. Follow-up questions are allowed where clarification is required.

The apprentice may choose to end the assessment method early. The apprentice must be confident they have demonstrated competence against the assessment requirements for the assessment method. The independent assessor or EPAO must ensure the apprentice is fully aware of all assessment requirements. The independent assessor or EPAO cannot suggest or choose to end the assessment methods early, unless in an emergency. The EPAO is responsible for ensuring the apprentice understands the implications of ending an assessment early if they choose to do so. The independent assessor may suggest the assessment continues. The independent assessor must document the apprentice’s request to end the assessment early.

The independent assessor must make the grading decision.

The independent assessor must keep accurate records of the assessment. They must record:

• the apprentice’s answers to questions
• the KSBs demonstrated in answers to questions
• the grade achieved.

The independent assessor must use the assessment tools and procedures that are set by the EPAO to record the response to questions.

The interview should be recorded (audio only) for quality assurance and moderation purposes. The recordings will be kept safe and stored by the EPAO in line with data protection legislation and destroyed a maximum of 1 month after the period for the appeals process has passed.

Assessment location

The interview must take place in a suitable venue selected by the EPAO for example, the EPAO’s or employer’s premises.

The interview can be conducted by video conferencing. The EPAO must have processes in place to verify the identity of the apprentice and to ensure the apprentice is not being aided.

The interview should take place in a quiet room, free from distractions and influence.

Question and resource development

The EPAO must develop a purpose-built assessment specification and question bank. It is recommended that this is created in consultation with employers of the occupation. The EPAO must maintain the security and confidentiality of EPA materials when consulting with employers. The assessment specification and question bank must be reviewed at least once a year to ensure they remain fit-for-purpose.

The assessment specification must be relevant to the occupation and demonstrate how to assess the KSBs mapped to this assessment method. The EPAO must ensure that questions are refined and developed to a high standard. The questions must be unpredictable. A question bank of sufficient size will support this.

The EPAO must ensure that the apprentice has a different set of questions in the case of re-sits or re-takes.

The EPAO must produce the following materials to support the interview underpinned by a portfolio of evidence:

• independent assessor assessment materials which include:
  • training materials
  • administration materials
  • moderation and standardisation materials
  • guidance materials
  • grading guidance
  • question bank
• EPA guidance for the apprentice and the employer.

The EPAO must ensure that the EPA materials are subject to quality assurance procedures including standardisation and moderation.

Overview

This assessment method involves the apprentice completing a defined piece of work that has a real business application and benefit. The scope of the work completed must meet the needs of the employer's business and be relevant to the apprentice's occupation and apprenticeship. Work towards this assessment method must be carried out after gateway. Please note: the recommendations of the written project report do not need to be implemeted as part of the EPA, but there must be evidence of all the KSBs mapped to this assessment method being demonstrated during the EPA period.

This assessment method has 2 components:

• a project with a project output:
  • the project should involve the investigation of a defined topic (more details provided below)
  • the output should be a written project report that summarises the analysis undertaken during the investigation, and the resulting conclusions and recommendations

• apresentation with questions and answers.

Together, these components give the apprentice the opportunity to demonstrate the KSBs mapped to this assessment method. They are assessed by an independent assessor.

Rationale

This assessment method is being used because:

• it assesses understanding of a subject
• setting the topic post-gateway ensures the reliability and validity of the EPA, and allows the independent assessor to prepare appropriate questions pertinent to the presentation
• the written project report can be used to demonstrate the application of KSBs as they would occur in occupational practice. Producing a written project report reflects normal practice in the workplace for a compliance and risk officer, therefore this assessment method is appropriate for the role
• it provides the opportunity to use authentic workplace contexts, which increases assessment validity in relation to the occupational role
• it allows the apprentice to directly demonstrate KSBs relating to communication and presentation of information
• it can produce something that is potentially of genuine business benefit to the apprentice's employer
• it allows for the presentation of evidence and testing of responses where there may be a range of potential answers
• it can be conducted remotely, potentially reducing cost.

Delivery

The apprentice must write a report of a project that investigates a topic based on any of the following themes:

• a specific problem
• a recurring issue
• an idea or opportunity.

Examples of types of project that could be used for the written project report are:

• Exploring an opportunity that has a strategic relevance and the potential to add value to the organisation.
• Reviewing a current process, service or product to ensure it is fit for purpose and meets the current needs of the business.
• Analysing a specific problem that has been identified in the workplace and recommending a change plan to resolve or improve it.

The project output should be a written report summarising the analysis and findings of the investigation and the resulting conclusions and recommendations. Apprentices are not required to implement the recommendations of their report as part of the EPA.

The written report should be based on, or relevant to, the apprentice's work area and presented in a format relevant to the project topic. For example, a business proposal, a report to a committee or board, or a proposal for a change plan. The written report should be presented electronically or on paper.

This assessment method should typically take 6 weeks to complete. A suggested timeline might involve 2 weeks for research, 2 weeks for writing the report, and 2 weeks for planning the presentation. However, the suggested timeline is only guidance, and the timeline should align with organisational requirements.

Marking

The independent assessor will review and mark the project in a timely manner, as determined by the EPAO, and without extending the EPA unnecessarily. Similarly, all quality control processes will also be conducted in a timely manner, as determined by the EPAO.

Supporting material

EPAOs will produce the following material to support this assessment method:

• Independent assessor training materials
• Assessment specifications
• Grading guidance
• Question bank
• Assessment recording documentation
• Examples of projects.

To ensure the project allows the apprentice to meet the KSBs mapped to this assessment method to the highest available grade, the EPAO must sign-off the project’s title and scope at the gateway to confirm it is suitable. The EPAO must refer to the grading descriptors to ensure that projects are pitched appropriately.

The project output must be in the form of a written report and presentation.

The apprentice must start the project after the gateway. The employer should ensure the apprentice has the time and resources, within the project period, to plan and complete their project.

The apprentice may work as part of a team to complete the project, which could include internal colleagues or technical experts. The apprentice must however, complete their written project report and presentation unaided and they must be reflective of their own role and contribution. The apprentice and their employer must confirm this when the written report and any presentation materials are submitted.

Component 1: Written project report

The written project report must include at least:

• an executive summary (or abstract)
• an introduction
• the topic and scope of the investigation
• research outcomes
• data analysis outcomes
• discussion of findings
• conclusions and recommendations
• references
• an appendix containing mapping of KSBs to the report.

The report must also include:

• evidence for KSBs that cannot be demonstrated in the presentation and questions.

Work towards this assessment method can only commence after the apprentice has gone through the gateway process. The apprentice will typically have 12 weeks in total to complete their project once the EPAO has agreed the project title and scope.

In advance of the apprentice entering the gateway process, the EPAO must provide a generic specification for a range of qualifying projects, to enable the employer to select a project that will meet the requirements of the EPA. Note that the employer is not restricted to this selection; however, the project scope and title must be signed off at the gateway by the EPAO to ensure sufficient coverage of the assigned KSBs.

The written project report must have a word count of 2500 words. A tolerance of 10% above or below is allowed at the apprentice’s discretion. Appendices, references and diagrams are not included in this total. The apprentice must produce and include a mapping in an appendix, showing how the report evidences the KSBs mapped to this assessment method.

The apprentice must complete and submit the report and any presentation materials to the EPAO by the end of week 12 of the EPA period.

Component 2: Presentation with questions

The presentation with questions must be structured to give the apprentice the opportunity to demonstrate the KSBs mapped to this assessment method to the highest available grade.

The apprentice must prepare and deliver a presentation to an independent assessor. After the presentation, the independent assessor must ask the apprentice questions about their project, report and presentation.

The presentation should cover:

• an overview of the project
• the project scope (including key performance indicators)
• summary of actions undertaken by the apprentice
• project outcomes and how these were achieved.

The presentation with questions must last 45 minutes. This will typically include a presentation of 20 minutes and questioning lasting 25 minutes. The independent assessor must use the full time available for questioning. The independent assessor can increase the time of the presentation and questioning by up to 10%. This time is to allow the apprentice to complete their last point or respond to a question if necessary.

The independent assessor must ask at least 6 questions. They must use the questions from the EPAO’s question bank or create their own questions in line with the EPAO’s training. Follow up questions are allowed where clarification is required.

The purpose of the independent assessor's questions is to:

• verify that the activity was completed by the apprentice
• seek clarification where required
• assess those KSBs that the apprentice did not have the opportunity to demonstrate with the report, although these should be kept to a minimum
• assess level of competence against the grading descriptors.

The apprentice must submit any presentation materials to the EPAO at the same time as the report - by the end of week 12 of the EPA period. The apprentice must notify the EPAO, at that point, of any technical requirements for the presentation.

During the presentation, the apprentice must have access to:

• audio-visual presentation equipment
• flip chart and writing and drawing materials
• a computer.

The independent assessor must have at least 2 weeks to review the project report and any presentation materials, to allow them to prepare questions.

The apprentice must be given at least 2 weeks’ notice of the presentation with questions.

The apprentice may choose to end the presentation early. The apprentice must be confident they have demonstrated competence against the assessment requirements for the assessment method. The independent assessor or EPAO must ensure the apprentice is fully aware of all assessment requirements. The independent assessor or EPAO cannot suggest or choose to end the assessment methods early, unless in an emergency. The EPAO is responsible for ensuring the apprentice understands the implications of ending an assessment early if they choose to do so. The independent assessor may suggest the assessment continues. The independent assessor must document the apprentice’s request to end the assessment early.

Assessment decision

The independent assessor must make the grading decision. They must assess the project components holistically when deciding the grade.

The independent assessor must keep accurate records of the assessment. They must record:

• the KSBs demonstrated in the report and presentation with questions
• the apprentice’s answers to questions
• the grade achieved.

Assessment location

The presentation with questions must take place in a suitable venue selected by the EPAO for example, the EPAO’s or employer’s premises. It should take place in a quiet room, free from distractions and influence.

The presentation with questions can be conducted by video conferencing. The EPAO must have processes in place to verify the identity of the apprentice and ensure the apprentice is not being aided.

Question and resource development

The EPAO must develop a purpose-built assessment specification and question bank. It is recommended this is done in consultation with employers of this occupation. The EPAO must maintain the security and confidentiality of EPA materials when consulting with employers. The assessment specification and question bank must be reviewed at least once a year to ensure they remain fit-for-purpose.

The assessment specification must be relevant to the occupation and demonstrate how to assess the KSBs mapped to this assessment method. The EPAO must ensure that questions are refined and developed to a high standard. The questions must be unpredictable. A question bank of sufficient size will support this.

The EPAO must ensure that the apprentice has a different set of questions in the case of re-sits or re-takes.

EPAO must produce the following materials to support the project:

• independent assessor EPA materials which include:
  • training materials
  • administration materials
  • moderation and standardisation materials
  • guidance materials
  • grading guidance
  • question bank
• EPA guidance for the apprentice and the employer.

The EPAO must ensure that the EPA materials are subject to quality assurance procedures including standardisation and moderation.

Performance in the EPA determines the overall grade of:

• fail

• pass

• merit

• distinction

An independent assessor must individually grade the interview underpinned by a portfolio of evidence and written project report with presentation and questions in line with this EPA plan.

The assessment methods contribute equally to the overall EPA grade. The EPAO must combine the individual assessment method grades to determine the overall EPA grade.

Independent assessors must individually grade both assessment methods according to the requirements set out in this EPA plan.

Grades from individual assessment methods must be combined in the following way to determine the grade of the EPA overall. An apprentice must achieve at least:

• a pass in both assessment methods to be awarded an overall EPA pass
• a pass in one of the assessment methods and a distinction in the other EPA merit
• a distinction in both assessment methods to be awarded an overall EPA distinction.

An apprentice who fails one or more assessment method will be awarded an overall EPA fail.

If the apprentice fails one or both assessment methods, they can re-sit or re-take the method (or methods) at their employer’s discretion. The apprentice’s employer needs to agree whether a re-sit or a re-take of the method is appropriate. A re-sit does not need further learning, whereas a re-take does. The apprentice should have a supportive action plan to prepare for a re-sit or a re-take.

The employer and the EPAO should agree the timescale for a re-sit or re-take. A re-sit is typically taken within 3 months of the EPA outcome notification. The timescale for a re-take is dependent on how much re-training is required and is typically taken within 4 months of the EPA outcome notification.

If the apprentice fails the written project assessment method, they must amend the project output in line with the independent assessor’s feedback. The apprentice will be given 2 weeks to rework and submit the amended written project report.

Failed assessment methods must be re-sat or re-taken within a 6-month period from the EPA outcome notification, otherwise the entire EPA will need to be re-sat or re-taken in full.

Re-sits and re-takes are not offered to an apprentice wishing to move from pass to a higher grade.

The apprentice will get a maximum EPA grade of pass for a re-sit or re-take, unless the EPAO determines there are exceptional circumstances.

The EPAO must have reasonable adjustments arrangements for the EPA.

This should include:

• how an apprentice qualifies for reasonable adjustment
• what reasonable adjustments may be made.

Adjustments must maintain the validity, reliability and integrity of the EPA as outlined in this EPA plan.

Internal quality assurance refers to the strategies, policies and procedures that an EPAO must have in place to ensure valid, consistent and reliable EPA decisions.

EPAOs for this EPA must adhere to the requirements within the roles and responsibilities table.

They must also appoint independent assessors who:

• have recent relevant experience of the occupation or sector to at least occupational level 3 gained in the last 3 years or significant experience of the occupation or sector.

Affordability of the EPA will be aided by using at least some of the following:

• utilising digital remote platforms to conduct applicable assessment methods

• using the employer’s premises

• conducting assessment methods on the same day

This apprenticeship aligns with:

• The International Compliance Association (ICA) for Associate Member (AICA) or Professional Member

• The Chartered Institute for Securities and Investment (CISI) for Associate Member (ACSI) or Affiliate Member

• The Chartered Institute of Credit Management (CICM) for Associate Member (ACICM)

The level of membership may be subject to the mandated qualification completed on programme.