We are back with another podcast on Adventures in Compliance, where we consider the intersection of Sherlock Holmes and Compliance. Today, I visit The Adventure of the Creeping Man. From this story we take the Holmes utterance to Watson “Come at once if convenient—if inconvenient come all the same”. This informs today’s discussion how Boards of Directors can be more involved in compliance through more effective oversight of risk management.

Compliance Takeaways

  1. What is the role of a company’s Board in a compliance program?
  2. A Board should not engage in management but should engage in oversight of the Chief Compliance Officer. The Board does this through asking hard questions, particularly around risk assessment, risk identification and risk management.
  3. What are 6 principles for Board oversight of compliance?
  4. Define the Board’s role.

A.Foster a culture of compliance risk management.

B. Incorporate risk management directly into a compliance strategy.

C. Define the company’s appetite for risk around compliance.

D. Execute the compliance risk management process.

E. Benchmark and evaluate the compliance process.

5. CCO reporting to the Audit/Compliance Committee must be structured carefully to promote ethics and compliance. Here are five best practices to help guide the reporting.

a. Quarterly reports.

b. Executive session.

c. Sitting in on other reports.

d. Informal relationship.

e. Annual report to full board.

Join us tomorrow as we mine the story of The Lion’s Mane for its compliance lessons.