Over this five-part podcast series, I have visited with Thomas Sehested, founder and Chief Executive Officer (CEO), Valerie Charles, Chief Strategy Officer, and Peter Chang, Head of Customer Success, from GAN Integrity, Inc. (GAN). In this series we consider how the effective use of technology can drive not only a more effective, operationalized compliance program but make your business run more efficiently. In Part IV, I visit with Chang on the GAN approach to client success and how it acts towards continuous improvement of a compliance program.
Execution is where the rubber meets the road in compliance. For any Chief Compliance Officer (CCO) or compliance practitioner, having not only an effective tech strategy for compliance but one that is executed is critical. This is where Chang and his team at GAN can step to make a very big difference. He began by emphasizing that typically a CCO has come from the General Counsel’s (GCs) office or has some type of legal or other non-tech professional. While resources and head count are always an issue for a CCO, work on administrative matters can also put a strain on the compliance program. Chang said that one of the first conversations he has with a CCO is do they have an automated program to handle the administrative tasks and then couples it with measurable data which allows a CCO to move from a detect mode to preventative and even prescriptive. With this consistency, you can deliver a more robust risk management strategy to senior management and the Board of Directors.
Another challenge for many CCOs is how to interpret the data they receive from a tech solution. In short, what does it all mean? Chang said that when his team begins a project, they actually work backwards to figure out not only what type of metrics will be generated but what a CCO might need going forward. You want to be “very clear on what you are capturing in terms of reporting and what is needed to execute the compliance program.” Chang advocates starting your analytics at the transaction level and “rolling them up in to a state where you can see the big picture”. While it is obviously important for a tech solution implementation to be successful, if you work towards it from the beginning it can help to make things “clear and concise” at the end.
Next, we considered system deployment. This means both adoption of a tech solution and its continued and even expanding use. Chang and his team begin by putting the compliance program into the tech solution and then moves to train on the solution going forward. This training works not only for the compliance professionals present at deployment but those who might come into the corporate compliance function after deployment. Chang called this continuous adoption, which is working with each customer so they can grow and expand the use of the tech solution to not only cover the original issue(s) but expand the tech solution to meet new challenges.
This approach has some very significant and positive implication for the compliance professional. This is another way to talk about continuous improvement in a compliance program. Chang noted that is to make sure there is a 100% attention rate in order to stay relevant within the organization. Ensuring there is continued coverage to support not only from the home office level but also the county level, essentially partnering with corporate compliance to ensure that as it grows the tech solution is right sized for them. Chang said there are cases where GAN has started with “medium sized companies who later want to grow into bigger due diligence solutions for their compliance program. In those cases, we may help them right size the program and make sure that if there’s high risk vendors who they may need, there are additional reports and the tech solution is configured properly so that they can get additional reports that they need. And this is all part of continuously working with the customers and with them to ensure that their programs are right sized.”
Think about that for a moment as this is taking the concept of continuous improvement and adding an ongoing tech solution. This is one of the areas both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) discussed in their jointly issued 2012 FCPA Guidance, as Hallmark 9 in the Ten Hallmarks of an Effective Compliance Program. This is not simply taking data from your compliance program and feeding it back in to create continuous improvement, but it is using a tech solution to not only make your compliance program run more efficiently but using that same tech solution to help continuously improve your compliance program.
Such an approach uses the subject matter expertise (SME) of the tech solution provider to help the compliance professional come up with a more effective compliance program. For the compliance professional it is expanding out their reach and scope through the use of not only this tech SME but with the information from their own compliance program to create greater efficiencies and effectiveness.
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