Building a strong compliance management system is one of the priorities for a compliance officer in an organization. There is an international standard that provides the guidelines for establishing this system: ISO 19600. Although, indeed, the nuances of corporate culture, territorial regulations, and the unique characteristics of each organization prevent the existence of a single common compliance management system for the different organizations. But it is possible to identify essential elements that must be present in any of these systems.

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Essential elements in a compliance management system

The compliance management system is the structural support of an organization. It can be defined as a set of procedures that organizations must follow to conduct their business in accordance with local laws, industry regulations, and specifications that meet customer needs. For this compliance management system to be effective, the incorporation of the following elements is required:

Leadership

A successful compliance management system must be built on a solid foundation of ethics that is wholeheartedly endorsed by top management. There needs to be an unequivocal, visible, and active commitment to compliance. But even more than acting as support or having the right tone, the ISO 19600 requirements call for organizations to appoint senior compliance officers with adequate authority, and resources to manage the system.

Risks evaluation

Compliance problems can touch many areas of the business, and therefore it is necessary to know which are the most exposed. It is necessary to know the highest risks, and where to focus efforts to ensure full compliance. The risk assessment is designed to provide an overview of compliance obligations, and then identify high-risk areas to prioritize resources, and address with priorities.  

Procedures

The system now requires organizations to have additional standards and controls in place that include detailed due diligence protocols for evaluating business partners. In this sense, criminal records, financial stability, and evidence of inappropriate associations with government agencies, for example, can be analyzed. Ultimately, the purpose of establishing effective standards, and controls is to demonstrate that the compliance management system is more than intentions on paper.

Means

The organization must allocate appropriate personnel, and resources in quality, and quantity to effectively manage the system. Staff must have the appropriate training, culture, qualification, and experience requirements. Additional resources such as funding, administration, and monitoring tools should be considered.

Monitoring, and surveillance

Even after all ethical messages from top management reach the appropriate audience, essential standards, and controls are in place, the question is: are employees following the organization's compliance program? It is necessary to check it. Monitoring is a commitment to continuous evaluation for those in compliance programs. It allows the detection of problems in real-time and reacts quickly to remedy the findings.