December 23, 2013 - Some of the largest banks in the world are struggling to set up new compliance programmes that will satisfy the recently approved Volcker rule.

The rule is a key provision of the 2010 Dodd-Frank financial reform bill in the US and prevents banks from trading their own accounts via proprietary trading.

According to the Financial Times, compliance for some of the biggest banks is particularly important as the measure requires chief executives to confirm in writing that their company has processes that are "reasonably designed" to meet with the new regulations.

Many lawyers working on compliance for major institutions around the world are concerned by the ambiguity of the term "reasonably designed", due to its subjective nature.

Within the Compliance Program Requirement; Violations section of the rule the term is used frequently in reference to writing new policies and procedures, creating internal controls, setting up management structure to make accountability clear and independent testing and auditing.

The use of the term is making it difficult for major organisations to understand exactly what they need to implement.