The 2020 Update not only continued to emphasize the importance of monitoring and testing the effectiveness of a compliance program, but it spoke more about a Chief Compliance Officer (CCO) and compliance function utilizing data to engage in both continuous monitoring and continuous improvement. The DOJ for some time now has stressed the importance of leveraging data in order to have objective evidence around whether or not a compliance program is working effectively. Yet, as many CCOs are legally trained they are unsure about what See more +
The 2020 Update not only continued to emphasize the importance of monitoring and testing the effectiveness of a compliance program, but it spoke more about a Chief Compliance Officer (CCO) and compliance function utilizing data to engage in both continuous monitoring and continuous improvement. The DOJ for some time now has stressed the importance of leveraging data in order to have objective evidence around whether or not a compliance program is working effectively. Yet, as many CCOs are legally trained they are unsure about what some of the specific areas to be considered are in establishing quantifiable metrics to monitor for effectiveness.
Three key takeaways:
1. Create an inventory of compliance metrics.
2. Create your metrics based upon the 2020 Update.
3. Use these metrics for continuous monitoring and improvement. See less -
