The Illusion of Assurance: Why superficial “independent” reviews increase risk
Boards and licensees can no longer treat independent reviews as a tick-box exercise. OCG’s Australian insight explains how templated scopes, policy-only checks, weak sampling, and conflicted providers create an illusion of assurance, leaving firms exposed when outcomes and evidence aren’t validated. The piece argues for evidence-based, risk-weighted reviews that prove performance, client alignment, and defensibility, not just paperwork.
How to use these findings to strengthen global regulatory operations
Standardise assurance globally: Set a group-wide methodology for independent reviews (clear ToR, sampling logic, evidence standards, escalation paths) so boards can compare results across regions.
Test outcomes, not just policies: Require reviewers to validate advice suitability, control effectiveness and client impact, with a documented chain from data → analysis → conclusion.
Separate independence from delivery: Avoid “reviewing your own work”. Ensure providers are genuinely independent of prior design/implementation to remove bias and false comfort.
Adopt scalable QA (e.g., FRaaS patterns): Use consistent, sample-based file reviews to monitor adviser quality, complaints handling, and due diligence, complementing internal QA and providing board-ready reporting.
Link assurance to governance cadence: Embed findings into risk committees, remediation backlogs and executive scorecards so issues translate into accountable action.
Read the full Australian article: The Illusion of Assurance: why your Independent Review may be putting you at risk.