How can you really know that your company’s compliance program is working?

You can hire a compliance consultant to review your procedures. And you can review what your competitors’ programs look like, and compare your own company’s. But peer reviews and benchmarking focus on whether an organization has an effective compliance framework, such as policies, procedures and training—along with a mechanism to monitor compliance. Yet neither is very effective at detecting specific conduct and compliance “soft spots” that may put a company at risk of violating the law.