up during earlier conversations are addressed by your strategic plan. Test this plan in your meetings with select Ĵļ²ăÕñĔĆÑÕİĴʰÕʣëʣʞ &cʞ; ʱļĔ solicit their feedback. • cĭļõČõşÕËĔĴļʣEêŘĔŁ²İÕţĆĆõčë ²čÕŗõĴļõčë &cĴÕ²ļʞŘĔŁ may face pressure from the business to optimize existing program costs. To manage this ÕŗĭÕËļ²ļõĔčʞŘĔŁĴñĔŁĆÑʝ • Benchmark compliance program spending against that of peers. • Identify where compliance can streamline its
culture and existing compliance ĭİĔëݲČõčñ²čÑʞļñÕţİĴļĴļÕĭõĴ to evaluate current compliance elements, initiatives and structures. Avoid the temptation to solve problems or even render judgments at this stage. Rather, the chief priority should be benchmarking compliance’s functional maturity and conducting analyses that will provide insight into pressing issues and internal information that will perspectives on the compliance program. Have functional leader meetings and identify how each leader feels about the current compliance program. inform the strategic plan. • Understand stakeholder • Understand the compliance team’s perspectives on the compliance program. When interacting with direct reports and key team members, pay close attention to their sentiments about the current compliance program and your transition. • č²ĆŘşÕĭİĔëݲČĴļ²êţčë and spending. Understand how compliance’s budget is allocated and request a ļñİÕÕʴļĔţŕÕʴŘÕ²İѲĴñÊĔ²İÑ of compliance spending. Conduct a benchmarking exercise to understand how current compliance spending ²čÑĴļ²êţčëËĔČĭ²İÕĴļĔŘĔŁİ peers. (The benchmark can also help you plan future program developments and make a budgeting case to the board.) Whether entering a previously created compliance program or building from the ground up, assess the current state of the function and conduct a gap analysis for a robust vision of organization wide
compliance performance. Proper planning prevents poor performance With an understanding of the current compliance program’s ĴļİŁËļŁİÕʞĴļ²êţčëʞÊŁÑëÕļ²čÑ performance, develop a strategic plan that addresses any issues you have uncovered. • Use peer data while creating investments, activities and staff allocation compare with your peers. • Develop metrics and create a progress tracker. Create metrics that effectively capture progress for activities in your strategic plan. Set up a progress tracker ŖõļñĴĭÕËõţËČõĆÕĴļĔčÕĴ²čÑ ²ËËĔŁčļ²ÊõĆõļõÕĴêĔİļñÕţİĴļɾɽɽ days to demonstrate program progress. • Meet with key stakeholders to solicit feedback. Assess how stakeholder concerns brought your strategic plan. While building your program’s strategy, assess how your “[T}he chief priority (of ² &cʮĴţİĴļɷɶɶѲŘĴʠ should be benchmarking compliance’s functional maturity and conducting analyses that will provide insight into pressing issues and internal information that will inform the strategic plan.
requirements through tailored training and improved controls.
• Find investment
opportunities that will maintain program effectiveness while supporting business needs.
• Focus on data analysis.
Data analysis is becoming increasingly important for legal and compliance risk
management. More than ever before, regulators and other stakeholders have increased their attention on data informed program management. New analytics initiatives should align with strategic business goals ²čÑĴĭÕËõţËÑÕĭ²İļČÕčļčÕÕÑĴʣ
Without execution, strategy is useless
Now it is time to deliver visible results. Monitor progress closely to ensure obstacles to execution are dealt with swiftly and continue information gathering internally to õļÕݲļÕļñÕĆĔčëÕİʴļÕİČĭĆ²čʣ
34 | March 2024
From the archives: Your first 100 days
CCI Magazine
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