Providing Effective Compliance Oversight

Analiese Fusner

The first element of an effective compliance program is high level oversight and leadership commitment. In a nutshell, a compliance & ethics program must designate leaders to oversee the implementation and operation of the compliance & ethics program.

There are four critical leadership components needed in creating effective high level oversight, they include:

1.  Board, Board Audit Committee, and CEO – “Tone at the Top”

Board members must provide strategic leadership, stewardship and governance. Additionally, the CEO, directors, and upper management must be committed to upholding the program through maintenance of the highest standards of responsibility and ethics.

2. The Chief Compliance Officer (CCO)

This position is arguably the most in-demand role today; and yet, the most misunderstood. Below is a list of some key roles and responsibilities for the CCO:

• Oversees implementation of the Compliance & Ethics’ Program (C&EP)
• Provides high-level scorecard of annual C&EP performance to Board and Audit Committees
• Internal resource/expert for the compliance program elements and implementation
• Chairs the C&EP Steering Committee
• Promotes the C&EP – awareness is key
• Applies Lean principles to eliminate duplicative audits

3. Compliance & Ethics Steering Committee

The steering committee is made up of cross-functional senior leaders and is critical in driving the following initiatives:

• Promotes & maintains integrity of C&EP
• Key ambassadors to the C&EP
• Provides the resources and owns areas of compliance activity
• Participates in annual enterprise risk assessment

4.  Sub-Committees

The sub-committees support high-risk areas of compliance and are comprised of employees who are subject matter experts who report to the leaders of the compliance committee. They are responsible for executing the compliance program work plan and helping cast a broader net by engaging and incorporating the program further into operations. Since the sub-committees report to the compliance committee, best practices are to ensure the chairperson or at least one sub-committee member is also on the compliance committee.

Establishing leadership and protocols for oversight are critical to the success of any compliance program.

Click here to view a Webinar providing more information about creating an effective compliance program.

Analiese Fusner is RevSpring’s chief compliance officer. She can be reached at afusner@revspringinc.com.