In this chapter, we will consider innovation in compliance from a variety of angles including artificial intelligence (AI) and computer technology (ComTech), structural innovations, tools and tactics and innovation in leadership. This will provide you a number of solid ideas you can use to move your compliance program forward. Begin by considering the starting point, which is an innovation strategy. In the most recent DPAs and NPAs issued by the DOJ they all include an element along the following strictures:

The Company will conduct periodic reviews and testing of its anti-corruption compliance code, policies, and procedures designed to evaluate and improve their effectiveness in preventing and detecting violations of anti-corruption laws and the Company’s anti-corruption code, policies, and procedures, taking into account relevant developments in the field and evolving international and industry standards.

This means that the DOJ expects innovation in your compliance program to keep up with evolving international and industry standards. This requires you to implement an innovation strategy.

Three key takeaways:

  1. Both the DOJ and SEC expect innovation in your compliance program.
  2. Innovation in compliance should have a strategy going forward.
  3. The key is to demonstrate how the compliance innovation will benefit the business going forward.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit this month’s sponsor Affiliated Monitors at