Is Tunnel Vision Undermining Your Compliance Program?

Risk and Compliance Magazine
April/June 2015

In this article, Barbara Linney discusses the importance of a holistic approach to risk analysis and compliance in today's increasingly complex regulatory environment. "Failure to consider the complete regulatory picture can result in compliance oversights and inefficiencies as well as unanticipated consequences of guilty pleas or settlement agreements," she said. Companies with global footprints are in a particularly precarious position as they "must navigate a minefield of laws and regulations governing international trade and business -- economic sanctions and asset freezes, export controls and customs and anti-corruption laws, to name just a few," she added.

In the face of complexity, many global organizations have adopted a "stovepipe" approach in which separate compliance personnel with specialized expertise oversee each area of regulation within each country in which operations are based, resulting in higher costs and a lack of coordination and communication. This "tunnel vision" can also have significant implications for the approach to resolving anti-corruption and other criminal matters. "A conviction for anti-corruption or criminal violations can snowball into a whole host of additional problems, including ineligibility for government contracts and export licences, False Claims Act liability, and so on," Linney said.

Specialists are needed but Linney emphasized that the big picture is equally important. "Care must be taken to ensure appropriate coordination and collaboration at all levels within the organisation's compliance structure, as well as coordination and collaboration with other key departments," she said.

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Is Tunnel Vision Undermining Your Compliance Program?