Tag Archives: Sean J. Griffith

Measuring Compliance

by Sean J. Griffith*

Regulatory and enforcement authorities are increasingly pressing firms to demonstrate the quality of their compliance program by reference to metrics.  For example, in a recent interview, Hui Chen, the DOJ’s Compliance Expert stated that “strong compliance must be data driven” and emphasized that “the kind of data [firms] do and do not monitor tells me a lot about how sophisticated their program is.”[1]  This is a fairly clear signal from the DOJ that firms must develop metrics to measure compliance or risk losing mitigation for having an “effective” compliance program. Continue reading