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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Yesterday’s ‘Polaroid compliance’ gives way to new era

It’s easy to get caught up in the dogma of how compliance programs have historically been managed.

But the biggest drawback to traditional compliance programs is the “snapshot” approach of one-time screening, one-time training, one-time reporting, etc. This is what’s referred to as “Polaroid compliance.”

Providing a snapshot used to be sufficient. Not any more. With advances in technology driving the ever-evolving landscape of compliance, Polaroid compliance can no longer compete with new approaches or fulfill the government’s requirements.

It is clear in the Hallmarks of Effective Compliance Programs set out in the DOJ-SEC Guidance that continuity is an important measure for evaluating a compliance program.

But how can this continuous program-monitoring be implemented in a cost-effective way?

Even the DOJ and SEC now acknowledge the power of web and cloud-based compliance solutions to accomplish this:

‘[W]eb-based . . . systems can be a good way to conserve corporate resources while, if properly implemented, preventing and detecting potential FCPA violations.’ (DOJ-SEC Guidance, page 58)

That recommendation from the enforcement agencies is spot on.

As I’ve discussed in other posts, new technology is redefining “effective compliance programs,” and doing it at a fraction of the cost.

Don’t let your company operate a “Polaroid compliance” program.


For more information about ethiXbase and the compliance solutions it provides, please contact Harry Cassin  here

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