Compliance convergence originates in the idea that many, if not all, compliance programs involve the collection and processing of information. What makes compliance convergence not only possible but almost inevitable is that many different functions within an overall compliance program look for the same information. Yet in many—if not most—organizations, information is not shared between compliance functions, tools that analyze information in one context are not utilized in others, resources dedicated to one area don’t cross-pollinate or otherwise make their information, decisions, or even their experience available for other areas.
Let’s spend a moment on a compliance officer’s most frequent effort, the root cause analysis. Compliance until fairly recently has been immune from the relentless drive toward efficiency that has engulfed the business world. In a lot of companies, there was fear that “efficiency” meant “budget cutting,” and that regulators would not look kindly on budget cutting in compliance. But efficiency means more than controlling spend on a Salary and Benefits budget line. And because compliance is notably bereft of businesspeople, there isn’t the natural drive to get the most out of each dollar. In a lot of cases, especially in a crisis, there’s a spare-no-expense mentality that morphs into wildly useless expenditures on accounting firms and outside counsel, and on implementing their sometimes-overly-cautious recommendations. Even recently, efforts to control costs within compliance programs have revolved around staff cuts or reassignments, rather than engaging in a true effort to identify and implement efficiencies.
The other root cause of compliance inefficiency—and one more relevant to the concept of convergence—is the subspecialization that regulations require. Companies handle life risk by risk. Banks have anti-money laundering risk, sanctions risk, FCPA/anti-corruption risk, operational risk, plus others. They hire experts in each field to develop programs to assess and mitigate those risks. Those experts develop their programs in somewhat of a vacuum. They buy technology they “need,” they write up resource requirements, they write policies, develop procedures, and create training. There is no overarching analysis, however, that would identify potential efficiencies among the various risks.
via Creating Efficiencies In Your Anti-Corruption Compliance Program – Forbes.
