Continuous improvement can come in many different, shapes, sizes and packages. As with all things compliance, you are only limited by your imagination. Have you ever thought about a tech implementation as a way for continuous improvement? Probably not but it is also a way forward for continuous improvement. Think about that for a moment as this is taking the concept of continuous improvement and adding an ongoing tech solution. This is one of the areas both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) discussed in their jointly issued 2012 FCPA Guidance, as Hallmark 9 in the Ten Hallmarks of an Effective Compliance Program. This is not simply taking data from your compliance program and feeding it back in to create continuous improvement, but it is using a tech solution to not only make your compliance program run more efficiently but using that same tech solution to help continuously improve your compliance program.
Such an approach uses the subject matter expertise (SME) of the tech solution provider to help the compliance professional come up with a more effective compliance program. For the compliance professional it is expanding out their reach and scope through the use of not only this tech SME but with the information from their own compliance program to create greater efficiencies and effectiveness.
Three key takeaways:
- Even in continuous improvement, you are only limited by your imagination.
- The delivery of a tech solution for compliance can be beneficial in multiple ways.
- Start your analytics at the transaction level and move upwards.