FCPA

Good Compliance Is In Good Execution, Not Questions

on May 27, 2014

Asking good questions, as Tom Fox observes in his April 10 blog, “Asking Questions to Build Your Compliance Program”, is the key to opening people to new ideas and possibilities.  Tom mentions an article in the April issue of Inc. magazine entitled “35 Great Questions” where Paul Graham, Jim Collins and other business leaders looked at questions business leaders should be asking of themselves and their teams.  Tom’s perspective is that these questions also apply to compliance and ethics. These questions are thought provoking (If energy were free, what would we do differently?), introspective (Do I make eye contact 100 percent of the time?), and challenging (Who uses our products in ways we never expected?).

Taking Fox’s slightly orthogonal perspective, I think there are questions that compliance and ethics leaders know to ask, and they know what to do with the answers. Compliance and ethics professionals already know what to do with the answers to questions like which employees represent the greatest risk to the company? Which markets represent the highest risk based on our business transactions? Which suppliers require further and/or more frequent scrutiny based on our history of transactions and recent overlaps with high-risk entities?  Their challenge is in performing the data analysis that yields the answers to these questions.

Compliance can be tricky. It requires a lot of manual oversight, which is why many shy away from cumbersome data analysis. Even if they are able to find a quick way to run the data and do reporting, the analysis would need to be mostly manual. Big data used to require companies to employ data analysts just to read and derive insights from hard data. So, it is easy to see why it isn’t the questions that are tripping everyone up, it is in the execution.

At Oversight Systems, we have worked hard to deliver analysis to drive smarter decisions. For compliance and ethics professionals, we deliver turnkey analysis solutions that identify the highest risk employees, markets, and merchants that companies deal with on a daily basis. Our software also comes with a built in log that tracks every action surrounding potentially fraudulent spending via email.

Having the answers to the good questions and having them available when you need them, are the keys to taking actions that make sense.

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