Last month, I wrote about succession planning in the compliance department, an important concept we should always consider to avoid a big gap when the chief compliance officer, or anyone else playing a key role in compliance, steps down or retires. But another type of succession is an even more common problem for the compliance program.
Internal controls designed to prevent or detect compliance problems vary depending on people. We can’t automate every compliance-related control. There has always been, and I think always will be, an important place for human judgment in the processes we use to prevent and detect issues. Many review-and-approve steps and other essential procedures continue to require human involvement, and this involvement often benefits from the judgment that comes with experience.