Catelas: Best practices in compliance monitoring: From Detection to Prevention and Beyond
Posted: 3 June 2014 | Source: Catelas
Over the past 18 months the Department of Justice and Securities and Exchange Commission have signaled that companies need to increase their ongoing monitoring as a part of a best practices compliance regime. Compliance professionals need to be aware of the most recent developments which allow not only detection and prevention but the proscription of compliance program violations before they become violations of the Foreign Corrupt Practices Act. This article traces the evolution on such thinking and how ongoing monitoring can help a company operate a more robust and at the same time more cost effective compliance program.
As both anti-corruption compliance programs mature and companies seek to maintain a best practices compliance program one of the areas that has continued to evolve is that of monitoring. Further just as companies mature in their thinking so do the regulators such as the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). This has tools to become available to companies to move from using monitoring simply for detection to prevention of corruption violations. However now such tools are available to allow companies to become predictive in trying to head off violations, before they arise. The next step will be to use such tools in a prescriptive basis, not only to head off potential violations but to take active remedial steps to prevent such violations in the future and to document those steps.