Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following topic and question: Manifested Risks – How has the company’s risk assessment process accounted for manifested risks? I found this to focus as much on continuous improvement, as it did with risk assessment through the emphasis on the risks which have been established and demonstrated by the organization. In other words, were you monitoring the See more +

Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following topic and question: Manifested Risks – How has the company’s risk assessment process accounted for manifested risks? I found this to focus as much on continuous improvement, as it did with risk assessment through the emphasis on the risks which have been established and demonstrated by the organization. In other words, were you monitoring the risk that you have not only identified but also have revealed themselves to your organization? See less -