In this month’s podcast series, I consider what techniques to use to create continuous improvement in your compliance program. As the DOJ stated in the 2019 Guidance “One hallmark of an effective compliance program is its capacity to improve and evolve.” Its implementation should help you to uncover and evaluate areas of risk and opportunities for improvement. Moreover as your business changes over time, in such areas as the environments in which it operates, the nature of its customers, the laws applicable to it and industry standards; your compliance program must change as well. All of this simply means business is dynamic and your compliance regime must be so as well.

Continuous improvement through continuous monitoring or other techniques will help keep your compliance program abreast of any changes in your business model’s compliance risks and allow growth based upon new and updated best practices specified by regulators. A compliance program is in many ways a continuously evolving organism, just as your company is constantly evolving.

Three key takeaways:

  1. Your compliance program should be continually evolving.
  2. Have a mechanism to incorporate lessons learned from oversight into your compliance program.
  3. The DOJ and SEC will give meaningful credit to thoughtful efforts to create a sustainable compliance program if a problem is later discovered.

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