It’s the most wonderful time of the year… no, not the holidays – Budget Season! It’s the time we cry and fight and claw our way into next year, making the case for what we need. Sometimes you know exactly what is called for, but other years it can be difficult to know what to request. No need to worry, we’ve got you covered. Here’s the ultimate checklist to get what you need.
1. Third-Party Due Diligence Reports
A risk-based approach to due diligence necessitates that higher-risk third-parties receive greater due diligence than lower-risk third-parties. You need to have budget to request deeper dive reports – whether that means that a human who speaks the local language is performing a deep-dive desktop review, or, for your highest-risk third-parties, an on-the-ground review including reputation checks from various sources. These reports can get expensive, but having a budget for at least a few will make your program significantly more defensible if there’s an investigation.
2. Travel/Training Budget
Everyone knows that the most effective training is done in person. There’s nothing like being on the ground in a high-risk territory to find out what’s really happening. You can answer questions in real-time during training, and follow-up to ensure that people understood what you were saying. Asking for a travel budget is critical. If you can’t get a travel budget, at least try to get budget for an online face-to-face tool like Zoom or Adobe Connect. Seeing someone’s face is the best way to engage.
3. A Professional Risk Assessment
The DOJ’s recent Evaluation of Corporate Compliance Programs guidance made it clear: if you don’t have a current risk assessment, you need to make it your priority to get one…