Department of Justice outlines the basics of a robust compliance program

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Last week, I attended Compliance Week 2022 in Washington D.C. The conference covered a range of topics from cybersecurity to human trafficking to privacy regulations. The general consensus was unsurprising- compliance is getting more complex and challenging.

A highlight of the conference was the passionate speech by Kenneth Polite Jr., the Assistant Attorney General, who explained,

“We will give significant credit to companies that build strong controls to help detect and prevent misconduct….

I also want to describe in detail about how we evaluate corporate compliance programs to ensure that companies are designing and implementing effective compliance systems and controls, creating a culture of compliance, and promoting ethical values.

We conduct that analysis at two different points: one when the misconduct occurred, and secondly at the time of the resolution itself. We use the same criteria at both times. As our guidance makes clear, we expect an effective corporate compliance program to be much more than a company’s policies, procedures, and internal controls. What we expect is that the company’s programs are well-designed; adequately resourced; empowered to function effectively; and last but not least, that they work in practice.”

Mr. Polite went on to explain that there is no one-size-fits-all and each company must tailor its compliance program to its operations and regulatory environment. The summary is quite simple – there are no shortcuts and you must build a robust and personalized compliance program if you want to stay ahead of the regulatory curve. Cookie cutter policies and procedures no longer cut it.

Nimonik strives to personalize its software solution to ensure the appropriate business units and responsible people are tracking their compliance obligations across the company.