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How to Combine Your Compliance Screening Requirements

Chris Doxey

Compliance screening and regulatory requirements used to be the concerns of financial institutions. Now all organizations and global corporations are accountable for compliance screening programs, ongoing internal controls, and applicable due diligence programs to ensure that suppliers, customers and even employees are not terrorists, enemies of the United States, money launderers, or Medicare and Medicaid fraudsters.

Chris Doxey explains how to combine your compliance screening requirements

The table below indicates which industry should be paying attention to a specific regulatory requirement. The table also indicates which financial processes are impacted.

Compliance Screening Requirements to Consider

Compliance Area Industries and Organizations Financial Processes

Foreign Corrupt Practices Act (FCPA)

All

Payroll, T&E, AP

Office of Foreign Asset Control (OFAC)

All

Payroll, T&E, AP, AR

Bureau of Industry and Security (BIS)

Global Companies

Payroll, T&E, AP

System for Award Management Security (SAM)

Government Contractors

Payroll, T&E, AP

Office of the Inspector General (OIG)

Health Care

Payroll, T&E, AP

The Sarbanes-Oxley Act of 2002

Generally Public Companies

Payroll, T&E, AP, AR, and GL

U.S. Sentencing Guidelines

All

Payroll, T&E, AP, AR, and GL

International ACH Transactions (IAT)

Global Companies

Payroll, T&E, AP, AR

U.S. Patriot Act and Consumer Identification Program (CIP)

Financial Institutions

Payroll, T&E, AP, AR

Standards for Attestation Engagements (SSAE-16)

Organizations Providing Services

Payroll, T&E, AP, AR, and GL

Anti-money Laundering (AML)

All

AR, AP, T&E, and Payroll

Know Your Customer (KYC)

All

AR

UK Bribery Act Regulations

Global Companies

AP,T&E

 

Important Tips

  1. Identifying the highest compliance risks for your industry and establish a strategy. Be sure to update your strategy as risks change.
  2. Prepare your data before the compliance screening process.
  3. Use a variety of sources when conducting your compliance screening. Be aware of international sanctions and updates.
  4. Define a due diligence process for each type of compliance screening process. Note the each regulatory compliance requirement may have a different matching process with variable types of “fuzzy logic.” Be careful to identify false positives across the organization while integrating data from several sources.
  5. Establish a schedule for your compliance screening process to ensure that all data is audited and received within an established deadline.
  6. Ensure that your due diligence process has clear audit trails and a well-defined escalation process.
  7. Establish roles and responsibilities for your compliance screening process to ensure validation and review.
  8. Implement a workflow process with a periodic audit process to ensure that periodic updates are occurring and that the process is properly working.

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