If a compliance professional discovers non-compliance, what is the FIRST step they should take?

When a compliance professional discovers non-compliance, the first step should be to conduct a baseline audit. This step is crucial because it allows the compliance officer to assess the extent and nature of the non-compliance issues that have been identified. By performing a baseline audit, the compliance professional can gather the necessary information to understand what went wrong, how the current systems may have failed, and where the organization stands regarding regulatory requirements.

A thorough audit serves as an essential diagnostic tool. It helps to identify specific areas of risk and concern, allowing for a more informed basis for subsequent actions. Following the audit, the compliance professional can then determine if corrective actions are needed, such as developing training or revising policies. This systematic approach ensures that any steps taken to address non-compliance are based on a solid understanding of the issues at hand.

In contrast, taking disciplinary actions or revising the compliance manual prematurely may not address the root causes of the non-compliance or may lead to changes that are not fully informed or effective. Similarly, developing a risk-specific education plan without first assessing the scope of the non-compliance might miss critical areas that need addressing. Establishing a firm understanding through a baseline audit is therefore essential for effective compliance management.