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What are the 7 pillars of compliance?

August 18, 20263 min read

What are the 7 pillars of compliance?

The seven pillars of compliance are written policies and procedures, a designated compliance officer and oversight, training and education, effective lines of communication, internal monitoring and auditing, enforcement of standards, and prompt response to detected problems. Unlike most numbered compliance lists, this one has an authoritative source: the US Federal Sentencing Guidelines, adopted by the HHS Office of Inspector General as the seven elements of an effective compliance program.

The seven, in order

  1. Written policies, procedures, and standards of conduct. The documented rules, available to the people expected to follow them.
  2. A designated compliance officer and compliance committee. Named accountability with enough authority and budget to act.
  3. Effective training and education. Delivered to the people whose work the policies govern, and recorded.
  4. Effective lines of communication. A route for raising concerns, usually including an anonymous one.
  5. Internal monitoring and auditing. Checking that controls actually operate, rather than assuming they do.
  6. Enforcement of standards through well-publicised disciplinary guidelines. Consequences that are known in advance and applied consistently.
  7. Prompt response to detected offences and corrective action. Investigating, fixing, and preventing recurrence.

Why this list carries weight

Most numbered compliance frameworks are teaching devices with no authority behind them. This one is different. It comes from the US Federal Sentencing Guidelines, and it matters because prosecutors and regulators use it to judge whether an organisation's compliance program was real or decorative. The HHS Office of Inspector General adopted the same seven elements in its compliance program guidance, which is why the list is most familiar in healthcare.

That gives the seven pillars a practical use the 5 C's do not have: they are a defensible structure to organise a program around when someone external is deciding whether you took compliance seriously.

How the pillars map to an audit

PillarWhat a SOC 2 or ISO 27001 auditor asks for
Written policiesThe policy set, with version history and evidence of approval
Compliance officerNamed owner, role description, evidence of oversight activity
TrainingCompletion records per person, per period
Lines of communicationThe reporting channel and records of what came through it
Monitoring and auditingControl test results across the observation period
EnforcementDocumented disciplinary standards, applied consistently
ResponseIncident records showing investigation and corrective action

Five of the seven produce evidence an auditor can sample. That is the useful way to read the list: each pillar has an artifact behind it, and a pillar with no artifact is an assertion.

Seven pillars, seven elements, or seven components

All three names refer to the same list. The OIG uses elements. Consultants often say pillars. Nothing turns on the difference.

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