We hear a lot about “Compliance 2.0” in our industry, but what does this really mean?
It means that compliance isn’t something a company does in the “ivory tower” of the C-suite or internal audit. Compliance is a part of what the organization does as a whole. Compliance 2.0 is for everyone, and everyone has to contribute. Very similar to the advent of Web 2.0, which was more about user-generated content, and getting more users involved as opposed to having a centralized authority.
The popular site, Wikipedia, is a great example of the power of Web 2.0.
Remember in the 90’s when you wanted to know something and you looked it up in the Encyclopedia Britannica? Full of factual, verified information but only on a limited set of topics. Now everyone turns to Wikipedia- a user edited site for fast facts and information on everything from celebrities to historical events. Wikipedia may not be perfect, but it still has a lot of really great information and on more topics than could ever be covered by the centralized Encyclopedia Britannica.
Similarly we’re seeing our clients leverage analytics to identify potentially fraudulent travel transactions while leveraging our case management tool to follow up on bad behavior. Making employees aware of a risky behavior means getting more direct users involved. It’s Compliance 2.0.
The Department of Justice is giving more and more credit in FCPA investigations to companies who demonstrate that compliance is an embedded part of how they operate. (See the Morgan Stanley and Ralph Lauren cases for examples.)
This obviously isn’t the perfect panacea for the point I’m trying to make about compliance, but the fact is that companies are no longer solely relying on a central group of employees to ensure compliance. By enabling technology to push awareness to the entire organization, employees now have to take on a certain amount of responsibility when it comes to following spending policy and ensuring that precious dollars aren’t lost to fraud, waste, and misuse.
Just like Wikipedia can cover more topics, so too can employees ensure more comprehensive compliance at any moment, in any situation.