As compliance professionals, we ought to and are expected to engage in continuous review and monitoring of our compliance programs for the purposes of ongoing improvement, advancement to help mitigate risk, and better fostering a culture of integrity in our organizations. I added no value to your day and have not told you anything new there.

However, I would propose that we’re often not thinking broadly enough about what can and should fall under the umbrella of monitoring and review that will positively impact our ethics and compliance programs. We tend to focus only on the substantive pillars of our programs and how behavior conforms to them, failing to give due focus and rumination to adjacent factors that directly affect the success of the execution of our programs.

Below I outline three ancillary elements of compliance programs that I encourage peers to take a dedicated look at, as part of their continuous review and monitoring.