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by InnReg on March 25, 2020

Staying Compliant in a Crisis

Categories: Compliance Consulting


The coronavirus crisis is continuing to unfold, resulting in both mandatory and voluntary changes to the ways in which we all do business.


Compliance is a business-critical function for all regulated entities. Even in an adverse situation, corporate officers remain liable for business continuity and compliance with all relevant regulations. Therefore, it is essential to respond to the operational impact of stay-at-home decisions that are made today as well as any additional restrictions mandated by authorities. It is also important to be mindful of the impacts of potential employee sick time and, unfortunately, even the potential of employee deaths.

Based on InnReg's experience with designing, implementing, and running compliance programs that include remote resources, we'd like to share some guidance to help you ensure smooth compliance operations in these challenging times.

  1. Review all workflows and procedures to determine which activities can be handled remotely assuming that compliance resources have access to relevant systems.
  2. Ensure that all resources have secure access to your internal and third-party systems, preferably through hardware that you manage. If that is not possible, at minimum, work with staff to help them set up appropriately secure VPNs. Make sure to keep an open dialogue between your compliance and IT resources to anticipate and address risk.
  3. Identify any operational changes that might occur with your third-party partners by paying close attention to any communications they provide, as well as through conversations with your relationship or account managers at those partner organizations.
  4. For any mission-critical tasks that cannot be handled outside of your operating locations, staff will still need to report to work. With your bare-minimum onsite staff, be sure to follow guidelines for social distancing and the disinfection of surfaces so that your office environment is as safe for them as possible. In addition, be sure that employees know that they not only can but must remain absent if they suspect they have the virus or have had contact with an infected person. The World Health Organization maintains a guide for proper protective measures
  5. Enable staff to succeed if they normally work in an office environment and must now work from home. Working from home can be an adjustment from finding a quiet workspace to managing distractions to coping with no contact with peers. Inc Magazine recently published an excellent guide to overcoming the challenges of a transition from working at home. Share this guide with all team members, be clear on your new norms and expectations, and potentially implement a “buddy system” pairing office workers with more practiced remote workers for both practical advice and moral support.
  6. Implement extra quality controls. This pandemic comes with a high level of uncertainty and concern, which places stress on your team and raises the probability of errors and omissions. Redouble all of your efforts at quality control, including closer monitoring of work products and transactions, higher sampling rates of quality checks, and greater scrutiny applied to any reviews and approvals. Extra vigilance will help prevent problems from slipping past your compliance controls.
  7. Take business continuity planning seriously. Ideally, you will already have fallback plans in place for what would happen if people or systems become available. In that case, you should now review those plans, ensure they would stand the test of likely coronavirus impacts, and then recommunicate those plans to everyone who carries out compliance processes as well as front, middle, and back-office staff. If continuity plans are lacking or absent, you cannot afford to procrastinate. Make or reinforce your continuity plans now, and do rigorous scenario testing (including running tabletop and live simulations) to make sure they work as well as they seem to on paper.

Although your business cannot control the pandemic or its impacts to your business, you can control the way you approach it. When it comes to compliance or any other mission-critical business function, the better your plans, the more calmly you can react, and the more confident you can be in successfully managing the impact of any disruption.

Moreover, there are resources that can help. InnReg is one of those resources. If you have any questions about your current compliance capabilities or how to adjust to further coronavirus scenarios, please contact me. I am happy to make InnReg's expertise available to you free of charge.

Contact me to discuss your situation. We will cover important steps to take, areas to pay particular attention to, and answers to any other questions you have.

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