Joe Murphy (joemurphyccep@gmail.com) is a Senior Advisor at Compliance Strategists, SCCE’s Director of Public Policy, and Editor-in-Chief of Compliance & Ethics Professional magazine.

In 2004, the U.S. Sentencing Commission amended the compliance program standards to make one of its most important improvements: It required companies to “evaluate periodically the effectiveness” of their programs. Other standard setters have followed. Sadly, I still see commentators mistakenly confusing this with auditing and monitoring or ignoring it completely. But evaluation is the key to having a program that works.