Build an evidence-driven compliance control room

Regulatory context

Compliance operations leaders need a precise understanding of obligations across jurisdictions to avoid redundant controls and to build automation where permitted. The sections below synthesise the foundational requirements that inform the rest of this guide.

United States: statutory and prosecutorial expectations

Sarbanes-Oxley imposes management and auditor attestations on internal controls over financial reporting. Section 404(a) requires management to state responsibility for establishing adequate internal controls and to assess their effectiveness annually, while Section 404(b) mandates external auditor attestation for accelerated filers.^{Sarbanes-Oxley Act of 2002, §404} Section 302 reinforces quarterly certification obligations for CEOs and CFOs, compelling them to disclose control deficiencies and fraud. Compliance operations must therefore maintain year-round evidence of control performance, remediation tracking, and disclosure controls.

The DOJ’s 2023 Evaluation of Corporate Compliance Programs instructs prosecutors to test whether compliance functions have timely access to operational data, how frequently they monitor transactions, and whether policies are integrated into business processes.^{DOJ Evaluation of Corporate Compliance Programs (June 2023)} The guidance emphasises three pillars: (1) design and comprehensiveness, including risk assessments and resource allocation; (2) how programs are implemented and whether controls work in practice; and (3) outcomes that show effective remediation and discipline. Compliance operations must anticipate prosecutorial inquiries by structuring data repositories, communications tracking, and escalation workflows in advance.

The U.S. Sentencing Guidelines Manual Chapter 8 provides additional incentives. Organisations that demonstrate an effective compliance program can receive reduced penalties if an offense occurs.^{U.S. Sentencing Guidelines Manual, Chapter 8} Key criteria include high-level oversight, adequate resources, periodic evaluation, and systems for reporting without fear of retaliation. Compliance operations must therefore document governance forums, budget decisions, training completion, and hotline analytics.

European Union: Digital Operational Resilience Act

DORA applies to banks, insurers, investment firms, and critical third-party providers operating in the EU. It mandates governance structures, risk management frameworks, incident reporting, resilience testing, and ICT third-party risk controls. Article 5 requires management bodies to define roles and oversee the ICT risk framework, while Article 11 directs firms to maintain incident classification criteria and reporting to competent authorities within strict timelines.^{Regulation (EU) 2022/2554} Articles 21–30 set out digital operational resilience testing, including threat-led penetration testing for significant entities every three years. Compliance operations must integrate these obligations into their monitoring schedules and reporting templates.

Article 32 introduces oversight for critical ICT third-party service providers, requiring contractual controls, reporting access, and exit strategies. Article 15 establishes a register of information on contractual arrangements, and Article 17 demands risk assessments before entering or renewing contracts. Compliance operations must coordinate procurement, legal, and technology teams to maintain complete supplier inventories and ensure that risk assessments meet regulatory expectations.

The European Banking Authority, European Securities and Markets Authority, and European Insurance and Occupational Pensions Authority issued a joint roadmap in October 2023 for DORA Level 2 measures, including regulatory technical standards on incident classification and reporting formats. Although secondary legislation is forthcoming, compliance operations must prepare to map data fields and reporting schemas to supervisory portals.

Singapore: MAS Technology Risk Management

The Monetary Authority of Singapore’s 2021 Technology Risk Management guidelines apply to financial institutions and include board-level accountability, risk assessment requirements, and resilience expectations.^{MAS Technology Risk Management Guidelines (January 2021)} Paragraphs 1.0.3 and 1.0.5 require boards to approve technology risk appetite and ensure resources for independent audits. Paragraph 5.1.1 mandates pre-implementation risk assessments for significant systems, while Paragraph 6.1.2 requires vulnerability assessments and penetration testing. Compliance operations must align their control testing calendars with these requirements and maintain documentation ready for MAS inspections.

The guidelines emphasise incident management (Chapter 8), requiring institutions to classify incidents, notify MAS promptly, and document root cause analyses. Compliance operations should establish integrated runbooks that connect security operations centres, legal, and communications teams, ensuring notifications occur within the timelines MAS expects for severe incidents.

Global harmonisation considerations

Multinational organisations face overlapping obligations. For example, DORA’s Articles 17 and 32 on third-party risk align with the DOJ guidance’s focus on third-party management and the U.S. Sentencing Guidelines’ requirement for due diligence.^{Regulation (EU) 2022/2554DOJ Evaluation of Corporate Compliance Programs (June 2023)U.S. Sentencing Guidelines Manual, Chapter 8} Mapping these intersections enables centralised control design while tailoring evidence packages to jurisdiction-specific reporting formats.

Compliance operations should maintain a regulatory obligations register that links each requirement to responsible owners, evidence repositories, testing cadence, and escalation triggers. This register becomes the backbone for audit preparation and supervisory dialogues, ensuring nothing depends on institutional memory or manual trackers.

Operational controls

Designing operational controls involves translating regulatory texts into measurable procedures and decision rights. The subsections below define the core components that transform compliance policy into daily execution.

Governance architecture

Establish a governance architecture with clear accountability layers. Sarbanes-Oxley requires the CEO and CFO to certify quarterly and annually, so compliance operations must enable management sign-off with confidence by providing dashboards of control status, open deficiencies, and remediation timelines.^{Sarbanes-Oxley Act of 2002, §§302, 404} Create a compliance steering committee chaired by the chief compliance officer, with participation from internal audit, legal, technology, and business unit leaders. Document meeting agendas, decisions, and action items in a central repository that maps to obligations.

For EU entities, align governance with DORA Article 5 by documenting the management body’s oversight responsibilities, including approval of the ICT risk management framework and review of performance metrics.^{Regulation (EU) 2022/2554} Record evidence of board briefings, training sessions, and challenge logs to demonstrate engagement. MAS TRM expects similar board oversight, so meeting minutes should highlight risk appetite discussions, technology investment decisions, and acceptance of residual risks.^{MAS Technology Risk Management Guidelines (January 2021)}

Risk assessment cycle

Implement a risk assessment cycle that integrates regulatory requirements and business changes. The DOJ guidance asks whether risk assessments are periodic, data-driven, and dynamic.^{DOJ Evaluation of Corporate Compliance Programs (June 2023)} Design quarterly risk refreshes that pull transaction data, loss events, audit findings, and regulatory updates into a scoring model. Document scenarios where risk trends trigger control redesign or additional monitoring.

For financial reporting, align risk assessments with Sarbanes-Oxley materiality thresholds, ensuring that any process impacting significant accounts undergoes walkthroughs, control mapping, and testing. For ICT risk, map risks to DORA Annex I domains, such as identification, protection, detection, response, and recovery. For Singapore operations, include MAS TRM’s emphasis on data centre resilience, access management, and third-party arrangements.

Control design and execution

Translate risk assessments into preventive, detective, and corrective controls. For financial reporting, maintain control matrices that specify control objectives, frequency, owners, evidence, and links to Sarbanes-Oxley assertions. Ensure testing plans align with Public Company Accounting Oversight Board (PCAOB) Auditing Standard 2201 requirements on internal control over financial reporting, especially for key controls supporting revenue recognition, inventory, and financial close.^{PCAOB Auditing Standard 2201}

For DORA compliance, implement controls for incident classification, reporting, and response. Create playbooks that align with Article 17 reporting timelines and Article 18 post-incident reviews.^{Regulation (EU) 2022/2554} Integrate these playbooks with MAS TRM requirements for incident notification and root cause analysis.^{MAS Technology Risk Management Guidelines (January 2021)} Document control operation through automated logs, screenshots, system exports, and approvals stored in a controlled evidence repository.

Third-party risk controls must comply with DORA Articles 28–32 and the DOJ’s third-party management focus. Establish due diligence workflows that capture risk ratings, contract clauses, monitoring schedules, and termination plans.^{Regulation (EU) 2022/2554DOJ Evaluation of Corporate Compliance Programs (June 2023)} Track completion of third-party training and certifications. Use dashboards to show coverage across vendor tiers.

Investigations and discipline

Chapter 8 of the U.S. Sentencing Guidelines requires organisations to promote and enforce compliance through incentives and disciplinary measures.^{U.S. Sentencing Guidelines Manual, Chapter 8} Establish intake channels (hotline, web portal, email) with confidentiality protections. Log cases in an investigations management tool that captures allegations, triage decisions, assigned investigators, evidence collected, remediation steps, and closure approvals. Maintain a disciplinary matrix that aligns outcomes with policy violations and tracks consistency across jurisdictions.

The DOJ guidance asks whether investigations are timely, well-documented, and subject to tracking by compliance leadership.^{DOJ Evaluation of Corporate Compliance Programs (June 2023)} Implement service level objectives for case triage and resolution. Link remediation actions to control owners and ensure follow-up testing occurs. Document communication with regulators when incidents implicate Sarbanes-Oxley disclosure controls or DORA incident reporting thresholds.

Training and communications

Sarbanes-Oxley Section 406 mandates codes of ethics for senior financial officers, while Chapter 8 of the Sentencing Guidelines requires effective communication of standards and procedures.^{Sarbanes-Oxley Act of 2002, §406U.S. Sentencing Guidelines Manual, Chapter 8} Build a training curriculum that covers financial reporting controls, technology risk management, third-party oversight, and speak-up obligations. Track completion rates, knowledge checks, and targeted follow-ups for high-risk roles.

MAS TRM Paragraph 11.0.1 requires institutions to train staff on technology risk awareness and incident response.^{MAS Technology Risk Management Guidelines (January 2021)} Align global training modules with local regulatory references, ensuring Singapore employees receive MAS-specific case studies and response drills. Document communications campaigns, policy acknowledgments, and leadership messaging to evidence tone from the top.

Tooling and automation

Compliance operations scale only when tooling captures evidence automatically, enforces workflows, and enables analytics aligned with regulatory expectations.

Evidence platforms

Deploy a control evidence platform that ingests logs, attestations, and artifacts directly from business systems. Integrate with ERP, identity management, and ticketing systems so control executions (such as access reviews, reconciliations, and approvals) automatically produce time-stamped evidence. Configure retention policies aligned with Sarbanes-Oxley recordkeeping rules and MAS TRM requirements for audit trails.^{Sarbanes-Oxley Act of 2002, §802MAS Technology Risk Management Guidelines (January 2021)}

Ensure the platform supports evidence segregation for DORA-regulated entities. Article 15 requires a register of contractual arrangements with critical ICT third parties, so include structured fields for provider identifiers, services, locations, concentration risk, and termination rights.^{Regulation (EU) 2022/2554} Provide reporting views that export the register for supervisory authorities.

Compliance analytics

Build analytics dashboards that combine transactional monitoring, control results, and hotline trends. The DOJ guidance assesses whether compliance programs leverage data to detect misconduct proactively.^{DOJ Evaluation of Corporate Compliance Programs (June 2023)} Create anomaly detection models for payments, travel expenses, and third-party invoices. Integrate ICT risk indicators such as incident counts, mean time to recovery, and patch backlog for DORA reporting. Provide drill-down capability to trace alerts back to source evidence.

Workflow orchestration

Use workflow engines to enforce segregation of duties, approvals, and escalation timelines. For example, access certification workflows should require reviewer attestations, capture evidence of review, and block completion without documented remediation of exceptions. Align workflow steps with PCAOB AS 2201 testing requirements and MAS TRM controls for privileged access.^{PCAOB Auditing Standard 2201MAS Technology Risk Management Guidelines (January 2021)}

Implement case management tooling for investigations that enforces DOJ expectations: documented intake, triage, investigation plans, and remediation closure. Enable integrations with HR systems for disciplinary action tracking and with SOX disclosure controls for escalations that may trigger public filings.

Regulatory reporting automation

Automate regulatory reporting pipelines. For DORA incidents, build templates that pre-populate Article 19 reporting forms with incident classification, impact assessment, and remediation steps.^{Regulation (EU) 2022/2554} For MAS TRM, configure notifications to send incident summaries to MAS within required timelines, including preliminary assessments and follow-up reports.^{MAS Technology Risk Management Guidelines (January 2021)} For Sarbanes-Oxley, integrate with disclosure committees to document material weakness assessments, remediation milestones, and external auditor communications.

Maintain an obligations calendar that aligns reporting deadlines with board meetings and audit committee sessions. Link the calendar to internal collaboration tools so stakeholders receive reminders, agenda packages, and pre-read materials. Include dependency mapping for third-party attestations, ensuring vendor deliverables arrive before regulatory submission deadlines.

Metrics and reporting

Compliance operations need metrics that satisfy regulators, inform leadership decisions, and drive continuous improvement. The metrics portfolio should cover control effectiveness, risk exposure, responsiveness, culture, and third-party oversight.

Control effectiveness

Track control testing results by category, including pass/fail rates, severity of exceptions, remediation timelines, and retest outcomes. Align reporting cycles with Sarbanes-Oxley quarterly certifications and DORA governance reviews.^{Sarbanes-Oxley Act of 2002, §§302, 404Regulation (EU) 2022/2554} Provide dashboards that segment control issues by business unit, process, and owner, highlighting trends in repeat deficiencies.

Include metrics on independent assurance activities, such as internal audit coverage, audit opinion results, and management action plan closure rates. For MAS TRM compliance, track the completion of independent technology risk assessments and penetration tests, documenting findings and remediation progress.^{MAS Technology Risk Management Guidelines (January 2021)}

Risk exposure and resilience

Measure inherent and residual risk levels across financial reporting, ICT, and third-party domains. Use heat maps that incorporate likelihood, impact, and velocity scores. For DORA, track incident severity distribution, mean time to detect, mean time to recover, and the percentage of incidents reported within regulatory timelines.^{Regulation (EU) 2022/2554} For Sarbanes-Oxley, monitor potential material weaknesses by aggregating control failures and quantifying exposure to financial statement assertions.

Responsiveness and investigations

Report investigation lifecycle metrics: time from allegation to triage, time to complete investigations, substantiation rates, and remediation completion intervals. The DOJ guidance highlights the importance of timely and thorough investigations, so dashboards should evidence adherence to service levels.^{DOJ Evaluation of Corporate Compliance Programs (June 2023)} Include disciplinary action statistics segmented by employee level and region to demonstrate consistent enforcement.

Culture and training

Track code of conduct acknowledgments, training completion rates, quiz scores, and survey feedback on ethical culture. Chapter 8 of the Sentencing Guidelines expects organisations to take reasonable steps to communicate standards and provide training.^{U.S. Sentencing Guidelines Manual, Chapter 8} For MAS TRM, report participation in incident response drills and tabletop exercises.^{MAS Technology Risk Management Guidelines (January 2021)}

Third-party oversight

Maintain dashboards on vendor onboarding timelines, due diligence completion, control testing coverage, and concentration risk indicators. DORA Articles 28–32 require comprehensive oversight, while the DOJ guidance evaluates third-party management programs during enforcement actions.^{Regulation (EU) 2022/2554DOJ Evaluation of Corporate Compliance Programs (June 2023)} Provide alerts for expiring certifications, contract renewals without updated risk assessments, and overdue remediation tasks.

Future watchlist

Compliance operations must track emerging regulatory developments to keep the control room current.

• U.S. Securities and Exchange Commission climate disclosure rules. While primarily focused on climate reporting, the SEC’s March 2024 final rule integrates with internal controls over financial reporting and disclosure controls, requiring compliance operations to coordinate assurance across ESG and financial teams.^{SEC Release No. 33-11275 (March 2024)}
• EU DORA Level 2 standards. Draft regulatory technical standards on incident reporting, testing, and third-party risk will define data schemas and minimum testing frequency. Compliance operations should monitor publications from the European Supervisory Authorities and prepare data models accordingly.
• Singapore Payment Services Act amendments. MAS consulted on expanding the Payment Services Act to strengthen user protection and financial stability, which will require adjustments to compliance monitoring for service providers.^{MAS Consultation Paper on Enhancements to the Payment Services Act (July 2023)}
• DOJ clawback pilot program. The DOJ’s March 2023 guidance on compensation incentives encourages organisations to design clawback policies tied to misconduct. Compliance operations should track implementation progress and measure effectiveness when seeking penalty reductions.^{DOJ Remarks on Compensation Incentives (March 2023)}
• Global operational resilience initiatives. The UK Prudential Regulation Authority’s Supervisory Statement SS1/21 on operational resilience and the Bank of England’s policy statement require identification of important business services and impact tolerances, influencing multinational compliance operations.^{PRA SS1/21 (March 2021)}

Embed these developments into the regulatory obligations register and schedule scenario analyses for potential control redesign. Use Zeph Tech’s DORA enforcement checklist and PCI DSS 4.0 enforcement briefing to maintain situational awareness.