When reviewing an organization’s compliance program, the primary consideration of enforcement agencies, such as the U.S. Department of Justice, is not how complex the program is by design or how much it costs to maintain. Their primary consideration is whether the program is effective, meaning is the program capable of consistently preventing non-compliance and detecting it immediately if it does occur, stopping further non-compliance.
Organizations that have enacted strong controls to prevent and detect misconduct can benefit tremendously from this investment should a violation occur. Regulatory expectations for effective compliance programs continue to increase steadily. This trend has caused compliance professionals and executives within organizations to continually re-evaluate the effectiveness of their compliance programs. These program assessments often highlight the inadequacies of many traditional compliance processes. The days of infrequent, sample-based audits or periodic hotline reports (that may only surface issues months or years after misconduct occurred) are no longer sufficient to meet regulatory expectations. Compliance modernization is of paramount importance for organizations seeking to satisfy regulatory expectations and proactively combat non-compliance.
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