Rely and Verify: RSF celebrates National Compliance Week


NOTE: RSF is celebrating National Compliance Week from Nov. 6-12.

Rely and verify describes what we do as a part of our compliance program. As such, we wanted to kick off National Compliance Week with a refresher on the importance of reliance and verification.

Auditing and monitoring are functions addressed in the Federal Sentencing Guidelines (FSG) for Effective Compliance Programs. The FSG mandates “organizations shall take reasonable steps to ensure the compliance program is followed, including monitoring and auditing to detect criminal conduct.”

Auditing and monitoring are very similar. However, audits are evaluations conducted by an individual independent from the operations being assessed and typically performed retrospectively (i.e., review past activities). On the other hand, monitoring is an ongoing assessment completed and reported on by an individual within the operations area.

So, who decides what should be audited versus monitored? At RSF, these decisions are defined in the organization’s compliance plan and identified and prioritized through the risk assessment process. The decisions are based on a variety of factors including but not limited to level of risk involved and whether the activity is new or existing.  As such, the determination as to when to audit versus when to monitor requires frequent reconsideration.

Verification activities are in place to protect the organization, its employees and customers. While compliance professionals have a chief role, everyone possesses some level of validation responsibility. Furthermore, for verification to be successful, we must be transparent by reporting the results of such verification.

As illustrated, teamwork and trust are the cornerstones of our compliance program. While we strive to build and maintain trust, we cannot lose sight of our responsibility to verify.

Thank you for taking the time to read and disseminate the first article in our National Compliance Week series.

If you have any questions regarding this memo, please don’t hesitate to contact one of your Compliance Officers at (843) 720-8462 or (843) 402-1197.

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