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Enhance your global compliance monitoring with a hybrid model

Vladimir Berezansky (vberezansky@ptc.com) is General Director of PTC Inc.’s Russian affiliate and Chief Compliance Counsel for PTC in Russia/CIS/CEE/MENA. Renee Martinez Sophocles (reneesoph@gmail.com) is the former Compliance Training Manager for PTC, based in Boston, Massachusetts, USA.

Although most compliance teams are careful to ensure robust implementation of their internal policies and protocols, a systematization of these processes is often lacking. At our organization, we were concerned that too much reliance was being placed on the internal audit function for these purposes, as internal audit was repeatedly covering much of the same ground to fulfill its role, which was deemed inefficient.

So for our compliance program, we decided to adopt an approach similar in spirit to that of: “Physician, heal thyself!” It remained unclear to us, however, how exactly to do this. Our team began a search for appropriate models and/or regulatory guidance that would help facilitate the implementation of a broadly scoped model for monitoring and surveillance of our own procedures. At the time of this internal discussion, the U.S. Justice Department (DOJ) Criminal Division and the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) issued unsolicited guidance, literally days apart, that we would eventually incorporate into our own model. In addition, we were further inspired by France’s Sapin II Law.

By combining key factors from all three of these sources, we developed our own internationally influenced hybrid model, which we will describe here.

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