Michael Volkov had this Valentine’s Day message for compliance managers:
The Justice Department has raised the stakes on anti-corruption compliance. DOJ prosecutors expect companies to have more sophisticated and mature compliance programs that are operational and not just conceptual.
Checking the box has been a temptation in the screening and risk mitigation business from its inception. Too many firms review regulations and ask what minimal steps can be followed to comply with them. Back in the day before documents were digitized, we called it “papering the file.” Good enough, however, is rarely good enough.
Check out Michael’s insightful article here: blog.volkovlaw.com
We apply the same caution when talking to clients about global sanctions. Some firms have looked at AML and KYC regulations and concluded what the minimum required process might be for checking names and entities against sanctions and watch lists. To some, making inquiry on a small number of sanctions lists checks the box or papers the file. It had to be done. It was done. Who cares if it could have been done better.
The philosophy at ISS reflects the old adage, If something is worth doing, it’s worth doing right. That’s a box we’ll check every time.