By Adam Turteltaub

There is a tendency to think of risk assessment as one thing and demonstrating the value of the compliance program as another. In this podcast, Catherine Bruno, Assistant Director Office of Integrity and Compliance (OIC) at the FBI shows that the risk assessment process can also be a great way to demonstrate the value of a strong compliance program.

So how do they make that happen?  First, the OIC ensures that individuals who are closer to the risk, the subject matter experts at each of the divisions at FBI headquarters, as well as each field office, are involved both from the start and on an ongoing basis. Every six months the OIC requires them to spend time assessing compliance risk and put forward at least one. This process ensures participation without demanding too much of the field’s time.

In advance of that meeting, the OIC conducts a training session, provides a model agenda, and may do a presentation on a particular risk area. They also require that, at the meeting, the participants also spend time examining the tier 1 risks that the OIC has identified.

In the future, she is looking to better spell out the cost of non-compliance and the savings of proactive measures. But, she cautions, quantifying the benefits does not have to be based on dollars exclusively. Reputational factors can and should also be considered.

Each field office is also required to provide data on the risk areas that they are tracking. That data gets compiled and gives them an opportunity to compare themselves to each other. The information is also shared at higher-level branch meetings a month later, and it helps executive assistant directors understand where field offices are focused in terms of their risks.

In sum, the process provides both a better understanding of risk and demonstrates the value of the compliance program.

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