Karen Nightingale and Jonathan Fox on Testing Your Compliance Program [Podcast]

By Adam Turteltaub

Auditing and monitoring of the compliance program is pretty standard these days.  Entain’s Karen Nightingale, Group Director of Ethics & Compliance and Jonathan Fox, Group Head of Ethics & Compliance Programmes, make the case in this podcast for going to the next level and actively testing your program. The two will also be addressing the topic at the 2025 SCCE European Compliance & Ethics Institute, which will take place in Lisbon, 10-12 March.

Doing so, they suggest, can turn a reactive compliance program into a proactive one by actively searching for points of weakness, identifying red flags in advance and addressing them early.

In practice, testing is more like an audit. It should be done periodically and provide an in-depth look at whether processes and controls are working as intended. By going deeper, it can uncover where there may be a weakness in what may appear to be a strong process as a whole.

To determine what controls to test, there are several factors. First is recognizing that your organization likely has limited resources: don’t plan a test that you don’t have the resources to carry out. Second, identify the taxonomy of risks and which fall within the compliance team’s remit. Next, prioritize the risks: identify the highest risks and start there.

As you do this work, ask for help from other parts of the organization. HR, legal, internal audit and others may all be great help.

Listen in to learn more, and then plan on attending their session at the 2025 SCCE European Compliance & Ethics Institute.

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