I was reading Tom Fox’s January 5, 2017 article “Technology, Compliance, and the Breakdown of Corporate Silos” in Compliance Week. It was particularly interesting.
Fox references a January 3 Wall Street Journal article by Angus Loten and John Simons (“Leadership Evolves Amid Tech Changes”) that states “data-driven capabilities are breaking down barriers between formerly siloed business units.” Fox suggests this advance provides limitless technological opportunities not previously available within compliance function.
For instance, Fox points to a recent Foreign Corrupt Practices Act (FCPA) enforcement action with General Cable Corp. as a good example of the potential power technology-driven insights. The company was caught with multiple bribery schemes involving several companies; details in the Non-Prosecution Agreement (NPA) clearly demonstrated General Cable Corp. was on notice for potentially illegal payments. And yet, despite those red flags, this critical information did not make it to the compliance function.
The benefit of information shared across business siloes means more cross-functional use of that information. Doing so requires business leaders employ a more collaborative style, thereby increasing the ability to raise issues of concern, suggests Fox. That factor expands the whistleblower concept regulators have strongly advocated. By eliminating bureaucracy, employees are permitted freedom to quickly voice concerns about questionable behaviors.
Fox concludes expanding a company’s digital footprint and platform will foster best practices, ultimately becoming a requirement for an effective compliance program among compliance professionals
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