Jeffrey M. Kaplan (jkaplan@kaplanwalker.com) is a Partner with Kaplan & Walker LLP in Princeton, NJ.

“Form follows function,” is a famous quote from architect Louis Sullivan. Too often, in my view, compliance and ethics (C&E) programs have an unduly narrow set of goals when it comes to identifying the function of a conflict of interest (COI) risk assessment, and this can lead to an unduly constricted approach to designing and conducting such assessments.

Of course, virtually all risk assessments — COI and other — have a goal of informing the board of directors and senior management with respect to C&E program oversight. As well, using risk assessment to help set audit priorities is near universal.