Set and Beat Your Benchmarks
See how your compliance program stacks up against your peers and learn new strategies to increase the effectiveness of what you’re already doing.
Achieving an effective ethics and compliance program requires more than simply adding rules and additional layers of controls. There must be an integrated effort that aligns financial and compliance requirements with the organization’s mission and values. The steps you take as a compliance professional should not be in isolation of your organization’s larger business objectives but in support of them.
Along with aligning with organizational goals, your compliance program can compound its impact by focusing on industry best practices that maximize efforts. This section will highlight the latest best practices in the use of technology, program automation and industry benchmarks to amplify the impact of key compliance program elements.
In order to detect and prevent non-compliance within an organization, robust documentation is seen as a critical piece for risk adversity. Here's insight as to why documentation is so important and tips on how to be better prepared for audits and other unforeseen circumstances.
In order to detect and prevent non-compliance within an organization, robust documentation is seen as a critical piece for risk adversity. Here's insight as to why documentation is so important and tips on how to be better prepared for audits and other unforeseen circumstances.
The following is a summary of what constitutes a proper documentation and paper trail, especially the fundamental factor of well written documentation in handing compliance matters:
Compliance Monitoring Program (CMP)
Design a comprehensive CMP with written remarks on each program that have been successfully implemented or rejected with justification. The remarks need to be reviewed and approved by the authorized Director(s) and it must be documented.
Compliance Checklist
Design a checklist for each compliance task and keep track on any exception noted. The exception noted must be accompanied with proper supporting documents which will act as an evidence and it must be documented.
Daily/Weekly/Monthly/Yearly – Compliance Review (DWMY-CR)
Design a DWMY-CR to plan the overall compliance job function in order to avoid any lapse or gap during the compliance review. The significant factor during the compliance review is to keep track of the paper trail. The paper trail consists of emails between staff and management, memos, letters, processes and any other type of document that tracks the history of an event.
Board Minutes
A paramount document, Board minutes clarify doubts within any circumstance. They must be well written with precise details such as what, how, who and when such action/event/remedy/person have taken place with proper deliberation. The minutes must be filed with appendices to track back what type of actions have been implemented and for ease of future references.
Regulator’s Audit Review Report
The regulator’s audit review report must be thoroughly read and replied with supporting evidence for each finding in the management’s comment. The replies must be detailed with proper justification of why such finding(s) occurred and the finding(s) must be corrected or rectified within a reasonable time period. The regulator’s findings and the replies must be deliberated in the Board meeting.
Conversely, the audit review report by the regulator does not safeguard in any standing as all audit reviews are conducted merely on “sampling basis”. The final audit review report is non-exhaustive, but it will carry its own weight during any investigation if the management’s comments are properly documented.
*https://www.fincen.gov/news/news-releases/fincen-and-manhattan-us-attorney-announce-settlement-former-moneygram-executive
**http://blog.volkovlaw.com/2017/05/moneygram-cco-pays-civil-penalty/
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