Vince Walden has posited that “the black box is dead”. He meant that there is no single tool to use to identify high-risk transactions, customer, employees or third parties. Yet, it is now even easier to ask big insightful questions from your data. Every compliance professional should embrace this.
Properly seen, compliance is a business process. As such you should keep in mind certain queries, such as:
- What are the company’s high compliance and ethics risks?
- Who within the organization is responsible for managing these risks?
- What controls are in place to manage these risks?
- Are these controls working? Are they effective?
- How do you know (or not) this?
The key is that through greater data mining and asking more insightful questions of that data you can truly move from a reactive-detect mode to a proactive-prescriptive mode.
Three key takeaways:
- The black box is dead.
- What is driving your risk scoring?
- Compliance as a business process must be driven by data.
