31 Days to a More Effective Compliance Program: Day 15 – Monitoring and Improving Internal Controls

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In this episode, we look at the ongoing process of monitoring and improving company internal controls. Christina Ravelo starts by posing fundamental questions about the frequency of manual approvals and control overrides, emphasizing the importance of continuous evaluation and recalibration. This episode highlights the misperception among many compliance professionals and lawyers that controls are static and unchanging once implemented. Instead, internal controls should be dynamic, requiring regular reviews and updates based on collected data, such as the frequency of overrides. Proper documentation is crucial, and companies should engage in periodic self-reviews as part of their continuous monitoring efforts. Ravello also stresses the necessity of identifying issues and remedying them to prevent further complications. Today’s key takeaways include the idea that control overrides are not inherently problematic if appropriately managed, the dynamic nature of internal controls, and the importance of a comprehensive monitoring process incorporating feedback from every line of defense.

Key highlights:

  • Understanding Control Overrides
  • Continuous Monitoring and Improvement
  • Assessing and Updating Controls

Resources:

Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast.

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