December 26, 2013

In this article, Jenner & Block Partner Erin R. Schrantz recommends the risk-based audit as an effective tool companies can use to measure the efficacy of their compliance programs, whether they relate to anticorruption laws or pharmaceutical regulations to European data privacy requirements or U.S. banking regulations.  She prescribes several steps that can be taken to ensure an effective assessment, including (1) identifying the business units within the organization that pose the greatest risk of violating the compliance area being audited; (2) identifying the employees within the business unit who may be in harm’s way; (3) gathering the right information; and (4) documenting the audit results and committing to remedial measures.