measure success by
numbers and costs.
For them, budget
discussions should be
the same for compliance
and other functions.
and in any case, it is not easy to measure
Evidence: Investigation/regulatory review
A comprehensive compliance program is a
program that, in times of a real test, would
serve the organization as a shield against
or even potential
A major issue
face when they are
is the ability to
that management has
invested enough to
ensure that processes
are aligned with the relevant regulation.
In any legal proceeding, judgment is based
on evidence; hence, the importance of
documentation and data mapping increases,
and the procedures that were improved
define relevant data as a potential “record”
for legal proceedings. The critical point in
time that reflects the organization’s program
effectiveness is the outcome of such an
investigation. If an organization could not
provide the relevant documentation to prove
right deeds, the result is regulatory sanction.
Investment: Financial measures
Another way to test how seriously the
program is taken by leadership is the price.
Business leaders measure success by numbers
and costs. For them, budget discussions
should be the same for compliance and other
functions. When senior managers heard
that my compliance team should be tripled
compared to previous year, they could not
understand why they should pay for such a
dramatic increase in operational costs. If cost
is increasing, leaders expect an improved
results. Isn’t that the case?
Any business operation should have key
performance indicators (KPIs). What should
be the KPIs for an ever-growing compliance
program that is a “cost center” and not
considered a “growth engine”?
is the price of an
In most cases,
companies fail when
they try to implement
a compliance program,
since they do not
expect and assess the
For an organization
that did not have a
compliance officer/team, recruiting one senior
expert is a 100% increase in terms of cost
and investment. Stakeholders may honestly
say they have done enough to align with
industry expectations and standards, but the
paradox is that once you start with the design
of a program, you just start to realize how
complex it is.
We are experiencing today the digital era in
which consumers expect to receive any type of
product or service electronically—web-based
Proactive and modern management will
search for the most up-to-date solutions that
will provide automated controls and reduce
labor compliance-related costs.
Currently there are no compliance
systems that provide end-to-end solutions to
compliance needs, and the question is, why?
Traditionally, banks and large corporations
increased the investment in compliance only
because they had to; therefore, the relevant