Chapter 3: Running an Effective Compliance Program

Developing Core Departmental Relationships

Compliance departments have a wide scope of responsibilities, yet compliance staff and budgets are limited. This makes building cross-functional partnerships important as a low-cost, high-return place for compliance departments to focus their energy. Cross-functional partnerships also allow compliance departments to ensure that their policies and procedures are integrated within the business, a key focus of the U.S. Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs.

A great example of why cross-departmental relationships are important comes up in third-party due diligence. Third-party due diligence programs are complex and one of the most resource-intensive, time-consuming components of a compliance program. If a compliance department tries to screen every third party on its own, it will quickly run out of time, not be aware of every third party, and become frustrated quickly. The reality is that third parties are selected and onboarded by the business. The compliance department should try to embed basic third-party due diligence within business processes, requiring compliance department involvement when elevated due diligence is necessary.

The DOJ has focused lately on whether policies have been “operationalized.” Its Evaluation of Corporate Compliance Programs makes inquiries regarding the “operational integration” of a company’s policies and procedures. It is a compliance department’s ability to get policies and procedures integrated throughout the organization that can make or break a program.

Opportunities for compliance departments to build relationships with other business departments are beneficial. Those relationships help mitigate risk, strengthen the compliance program, and improve organizational culture by leveraging the roles and responsibilities held by other departments. How can you initiate those important relationships? They often require a very simple first step: asking for a meeting. Coming into that meeting with specific areas for cross-departmental collaboration is critical, and learning about how the compliance program is or isn’t working in practice is just as important.

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