Monitoring and Improvement

Element Characteristics:

  • Regular, risk-based review of internal controls and overall program effectiveness
  • Findings tracked, reported, and responded to appropriately
Roles and Responsibilities:
Senior Leadership Compliance Operations
  • Review reports of risk-based monitoring activities and action plans
  • Review compliance program self-assessment results and approve action plans
  • Develop and implement risk-based compliance monitoring plans, and report findings as appropriate
  • Assess compliance processes and program effectiveness
  • Implement operational changes as needed to address monitoring findings
  • Self-assess adequacy of design and execution of controls