4. Promptness in auditing/reviewing: You
and I know. The Compliance area already has
a plan, a program; it should have it to know
what they will do and how much time will
be invested. But, there is a key element that is
forgotten—the agility to do their job. When
they start reviewing
some area or a
transaction, it could
be the lead to major
crimes such as fraud,
or tax evasion, and
timing is really
Because the criminal
could get away or
erase evidence. In
those cases, Compliance should be more agile
and effective. Yes, sometimes it’s fine to leave
the plan in order to follow the riskiest issue,
especially if Compliance needs to be more
positioned within your company; do it and
show effective results.
5. Positioning the area within the company:
In addition to being agile, Compliance staff
should be accessible, humble, and lead by
example. You could think, “Well, that is
obvious,” but it isn’t. History has shown us
that for several years (including 2017), the
majority of the Compliance areas within a
company lack this. What does this affect? To
start with, if employees don’t know where
to find Compliance and what to report to
them, what is the purpose of the area? If
Compliance is seen as someone conceited,
is someone going to approach them, even
though they know what to report to them?
And if Compliance doesn’t lead by example,
what kind of message are they sending?
Go back to discrimination. Positioning the
Compliance area is more important than you
think! If Compliance isn’t seen/perceived at
the same level as other areas are, its force will
be less, budget will be limited, and others
will think they are a “necessary evil,” rather
than an area that contributes to growing
the company. If you don’t believe me, check
this: Look for ads
for compliance jobs.
Most of them will
report to the Director
or the Legal
shows regard for the
little position the
Compliance area has
at the international
level in companies.
report to the CEO and to the Compliance
Committee; otherwise it loses independency!
Either external or internal concerns,
according to the circumstances of your
company, could become a risk. If they
become a risk, then the analysis should
start by addressing them and by testing
how effective the controls are that are
already in place to minimize them.
Just remember: risks are variable.
They change without notice. So, keep
an eye on external and internal factors
that may affect the company. This is only
a general overview of key compliance
concerns for 2018, but you are the expert in
your company. Use your knowledge and
experience, and do the appropriate magic to
make them disappear or at least minimize
Abracadabra, alakazam…good luck
1. Robert Hackett: “IMF Head: Cryptocurrency Could Be the Future.
Really.” Fortune, October 2, 2017. Available at http://for.tn/2x Yk9yG.
Mónica Ramírez Chimal ( firstname.lastname@example.org) is Partner and
Founder of her own consultant firm, Asserto RSC in Mexico City.
In addition to
being agile, Compliance
staff should be accessible,
humble, and lead by
example. You could think,
“Well, that is obvious,”
but it isn’t.