A strong corporate compliance program is never finished. It requires ongoing attention, adaptation, and refinement to keep pace with changing risks, evolving regulations, and the realities of your organization.
Over the last few years, expectations have shifted meaningfully. The Department of Justice’s Evaluation of Corporate Compliance Programs continues to emphasize the importance of dynamic, data-informed, and risk-responsive programs—not simply programs that exist on paper.
How do you know if your program is evolving fast enough to keep up? Here are three signs it may be time for a fresh look.
1. You’re relying heavily on participation metrics to demonstrate effectiveness
Tracking participation and completion rates is necessary—but on their own, they aren’t sufficient to demonstrate that a program is working. Regulators, leadership, and boards are asking sharper questions: How is the program influencing behavior? What evidence shows that employees understand and apply compliance principles in practice? Where are the biggest areas of risk or resistance?
If your program metrics stop at “how many” rather than “how well,” it may be time to expand your measurement strategy. Training that goes beyond repeating quiz questions (where employees can brute force their way by process of elimination) and gathers behavioral insights—employee decisions made in behavior-based simulations—provides a lens into where employees have clarity issues, misconceptions, and strengths, offering a more meaningful window into operational gaps and potential microcultures. And when those insights are paired with in-course remediation—such as targeted feedback and additional learning opportunities within adaptive compliance courses—they don’t just diagnose knowledge gaps, they help close them in real time.
In today’s environment, it’s not just about proving that employees completed compliance training. It's about showing how the program strengthens ethical decision-making across the business.
2. Compliance is primarily event-driven, not embedded into daily operations
If compliance is experienced as a series of annual events—a training session here, a policy acknowledgment there—it can easily become siloed from day-to-day decision-making.
Modern compliance programs are expected to do more than deliver information. They are expected to equip employees with the tools, resources, and mindset to navigate ethical challenges in real time, not just during scheduled trainings.
This expectation aligns with DOJ guidance, which underscores the importance of a program that is “adequately resourced and empowered to function effectively”—meaning compliance should be integrated into business processes, not operating in a vacuum.
Embedding compliance into the flow of work, creating real-time access to guidance, and making policies practical and actionable are all signs of an evolved, high-functioning program.
3. Your approach still treats all employees the same—regardless of risk exposure
Uniformity can create the appearance of fairness, but in compliance, a one-size-fits-all approach can actually increase risk.
The DOJ continues to emphasize the importance of risk-based training and communications—tailoring compliance training to an employee's role, geography, exposure to misconduct risk, and level of responsibility. Treating everyone the same often means under-serving high-risk groups and overburdening low-risk ones.
If your compliance training program doesn’t reflect the nuances of your organization’s risk profile—or if all employees receive the same content in the same way—it’s worth asking whether your efforts are truly fit for purpose. A more strategic, risk-driven approach ensures you are allocating resources where they can have the greatest impact.
The bottom line
An evolving compliance program isn’t one that abandons what’s working—it’s one that continuously questions, tests, and refines its approach to meet the demands of today and tomorrow.
It’s about moving beyond participation to impact. Beyond events to embedded culture. Beyond uniformity to targeted, risk-based action.
For many compliance teams, it’s not about whether to reimagine their program—but how to take the first step. Reflecting honestly on these three signs can offer a meaningful starting point to strengthen your program’s alignment with regulatory guidance and day-to-day business realities.
Harper Wells is a governance, risk, and compliance leader with over 20 years of experience developing enterprise-wide ethics and compliance programs. As Chief Compliance Officer at Learning Pool, she leverages data-driven insights and innovative training strategies to foster ethical, high-performing workplace cultures.
