In this opinion piece, David Lawrence, founder and chief collaborative officer of RANE Corp., points out that, “...a vigilant institutional effort is now needed… to audit whether online processes can be ‘gamed’ to falsify the records of course completion and test results.” Otherwise, corporations are leaving themselves open to potential legal, financial, and reputational risks, Lawrence and his co-authors write.

Compliance training and supervision has always been the first line of enterprise defense against legal, operational, and reputational risk. Now, it is increasingly the final line of defense that determines how enforcement officials view an institution and, in turn, exercise their considerable discretion in assigning liability for regulatory violations.

Corporations face an evidentiary burden built on the foundations of the late Sen. Howard Baker’s Watergate inquiries. Institutions must not only be able to respond to the question, “What did you know, and when did you know it?” They also must have a credible answer for, “What did you do to prevent this?”

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