People usually watch scary movies for the thrill. Others may watch it for professional inspiration, such as the editors at Compliance Podcast Network. They offer several lessons learned from the 1954 movie, Creature from the Black Lagoon, based on DOJ’s recent update to the Evaluation of Corporate Compliance Programs (ECCP), which may also give some of you nightmares.
- When entering new territory, keep an eye out for unknown risks. ECCP expects continuous assessment and identification of possible new risks, especially for new markets and products, new regulations, or dark lagoons with a scary soundtrack.
- Once a possible threat emerges, quickly assess the nature of the issue. ECCP emphasizes timely action to understand and incorporate risks into the compliance program. In real life, there’s no soundtrack to identify the good guys vs the bad.
- Quickly figure out what is needed to manage the threat. ECCP encourages compliance programs that quickly adapt to risk changes, including enhanced internal controls, third-party risk management, etc. Some creatures are very difficult to subdue so you’ve got to figure it out quickly and pass the word.
- Remain vigilant to avoid further attacks. ECCP’s recent update reinforced the value of data analytics and other real-time monitoring activities. We all know that scary things creep up on you.
- Everyone should be on the lookout and know what to do. ECCP recognizes that revised training programs and regular communications from leadership are essential to keeping all employees vigilant and understanding how to respond to issues, such as screaming or using hotlines.
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