Making It Happen
How do you move to the desired compliance process? The way is straightforward, although as with any change initiative there are potential pitfalls. Among the tried and true approaches is a multistep sequential process that looks at what currently is in place, determines where you want to be, and crafts an action plan for getting there. Also important is dealing with senior managers who might want limited resources devoted to other important business initiatives. With that in mind, here's a brief five-step outline of what experience shows works well.
1. Make the business case. Get a rough estimate of current costs involved in dealing with compliance matters, including the risks and costs associated with noncompliance events. Relate this to a streamlined process built into business operations, together with support personnel and the cost of the change initiative. It's important to include the benefit of enhanced program effectiveness and anticipation of fewer and less costly noncompliance events, and senior management and the board to have better information and greater comfort. Because CEOs and boards usually already recognize shortcomings of existing compliance efforts, they are generally receptive to a thoughtful rationale for building a truly effective and efficient compliance process.
2. Assess where you are. Consider the current or as is state, including an inventory of compliance policies and procedures—both written and unwritten—and authorities and support ...