31 Days to More Effective Compliance Programs - Day 24 - Updates and Feedback

Thomas Fox - Compliance Evangelist
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It is a function of the CCO to reinforce the vision and goals of the compliance function, where assessment and updating are critical to an ongoing best practices compliance program. If you follow this protocol, you will put a mechanism in place to demonstrate your company’s commitment to compliance by following through on intentions as set forth in your strategic plan. What should you do with this information? Put a strategic plan in place ready to implement your findings of continuous improvement by using the See more +
It is a function of the CCO to reinforce the vision and goals of the compliance function, where assessment and updating are critical to an ongoing best practices compliance program. If you follow this protocol, you will put a mechanism in place to demonstrate your company’s commitment to compliance by following through on intentions as set forth in your strategic plan. What should you do with this information? Put a strategic plan in place ready to implement your findings of continuous improvement by using the following:

* Review the goals of the Strategic Plan. This requires that you arrange a time for the CCO and team to review the goals of the Strategic Plan, which the CCO should lead to determine how this goal in the Plan measures up to its implementation in your company.

* Design and execution plan. The KISS method (Keep It Simple, Sir) is the best to move forward. This would suggest that there should be a straightforward plan for each compliance goal to ensure that the goal in question is being addressed.

* Put accountabilities in place. In any plan of execution, there must be accountabilities attached to them. This requires the CCO or other senior compliance department representatives to put these in place and then mandate a reporting requirement on how the assigned task is achieved.

* Schedule the next review of the Plan. There should be a regular review of the process. It allows any problems that may arise to be detected and corrected more quickly than if meetings are held unless frequently.

Continuous monitoring is a key step, but it is only the first step. It is not simply that you tested your compliance program but that you did something to improve your program with the information you obtained.

Three key takeaways:

1. Innovation can come through a new way to think about and use data going forward.

2. Have a plan to use the information garnered in your monitoring incorporated back into your compliance program.

3. Always remember that Document Document Document is critical if the regulators come knocking. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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