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.