Tag: Testing

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Compliance Into the Weeds

Compliance into the Weeds: Exploring Compliance Data Access and Testing Challenges

The award winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the study, 2024 Benchmarking Study: Testing & Monitoring and Data & Systems, jointly conducted by Radical Compliance and Rethink Compliance.

The study raises critical concerns about the access and effectiveness of data testing in compliance programs. While many compliance officers engage in some level of testing, there is a significant gap in comprehensive testing and access to necessary data across enterprises. Only a small percentage tracks key performance indicators (KPIs) at granular levels, such as individual or department, which are essential for understanding program effectiveness. The discussion also highlights the importance of access to data from different departments, like HR and Finance, to improve compliance monitoring and alignment with DOJ guidelines. The episode concludes with a call for continued research, emphasizing the interconnectedness of data access, comprehensive testing, and compliance success.

Key Highlights:

  • Overview of the Compliance Study
  • Key Findings and Statistics
  • Challenges in Compliance Testing
  • Importance of Multiple KPIs
  • Access to Data Issues

Resources:

Matt in Radical Compliance

2024 Benchmarking Study: Testing & Monitoring and Data & Systems

Rethink Compliance

 

Tom

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Corruption, Crime and Compliance

Episode 241 – Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program

The Justice Department and various regulatory agencies continue to emphasize the importance of continuous improvement, testing and review as part of robust assessment procedures in an effective compliance program. The Treasury Department’s Office of Foreign Asset Control has specifically stated that a sanctions compliance program should include “a comprehensive, independent, and objective testing or audit function” so that a company can determine “how their program[] [is] performing and should be updated, enhanced, or recalibrated to account for a changing risk assessment or sanctions environment.” The Health and Human Services — Office of Inspector General has made similar statements underscoring the need to conduct compliance audits and testing. An important part of every compliance program focuses beyond the design and operation of the program to the important issue of whether the program is working. In this respect, DOJ and regulatory agencies have noted that CCOs should be striving to develop “continuous” monitoring systems and avoid “snapshots” in time. In order to execute such monitoring, compliance has to maintain broad access to operational data across all key functions in a company. This data must be used to regularly update risk assessments, compliance policies and procedures and financial controls.

In this episode, Michael Volkov takes a broad review of the testing and auditing of ethics and compliance programs.