Stress Testing your Compliance Program

Image of track numbers for a road race

Is there anything like a good workout to get that heart rate up, blood flowing? It’s always better in groups, where you can cheer one another on to keep up the good work. Two examples of this come to mind: on the road, my dear colleague Charro would always be an inspiration to get down to the gym. Another example was when I entered the Tour De Patrick, three 5k races in March, and while my cousin had already finished, it was fantastic to hear “Keep it up, 1308!” from an encouraging stranger in the crowd. Nothing like a good push to get you over the finish line.

During one of my courses at Fordham Law, our professor placed us into groups for a number of assignments. The five of us, from a variety of industries, had to count on each other for our individual grades. In the end, our distinct experiences in compliance ended up serving our assignments very well. (I also came away with glimpses into financial and customs compliance, including examples of reverse false claims!)

I recommend you stress test your compliance controls by asking a trusted colleague to look under the covers. The program is not something you can touch and hold, so it should be in place whether everyone is onsite or you are working remotely. Don’t sit paralyzed waiting for your program audit notice; it is always a good time to put elements of the program through the paces, and document this monitoring effort. Are corrective actions being validated? Has it been a while since your last compliance risk assessment? Have you communicated recent compliance trends? When is the last time a “top-down” message about the commitment to compliance was issued? Perhaps they test the hotline, or they review the delegation oversight committee minutes. You don’t need to buy a Peloton or a wacky mirror with a personal trainer in it to get the blood flowing in your compliance program. As the saying goes: just do it!