A new initiative by the U.S. Department of the Treasury aims to promote fairer compliance and enforcement practices across its programs and services.
On June 8, Deputy Secretary of the Treasury Wally Adeyemo published a memorandum directed at Treasury Department bureaus and offices, laying out a framework to guide their compliance and enforcement efforts.
In a statement, Adeyemo described the initiative as part of a comprehensive strategy directed by Secretary Janet Yellen “to promote fairness and accountability in our compliance and enforcement efforts as we safeguard against waste, fraud, and abuse.”
The framework is rooted in the following four core principles:
Making it easier for individuals and entities who want to comply with the law to fulfill their obligations: This principle includes “making program rules and guidance more accessible and making application, filing, payment and reporting processes more user-friendly.” Helping people avoid errors on the front end mitigates unnecessary enforcement actions, Adeyemo stated in the memo.
Prioritizing enforcement efforts based on an appropriate consideration of relevant factors: Given limited resources, the Treasury Department “must strategically focus efforts on identifying and assessing the level of risks within each program to be most effective in efficiently increasing compliance, protecting the integrity of our programs, and ensuring that they continue to reach eligible people and function as intended.”
Investing in the personnel, technology, and other resources to investigate and resolve noncompliance efficiently: This principle includes “a data-centric approach for compliance monitoring to identify anomalies and patterns, and use of automated tools to reduce manual effort and increase efficiencies in compliance testing. Additionally, seeking opportunities to collaborate through technology and improve data sharing during the compliance monitoring lifecycle will help to identify compliance risks, Adeyemo said.
Promoting fairness, trust, and accountability in program administration and enforcement efforts: This principle entails having a “well-defined and documented compliance and remediation strategy…to create greater accountability and transparency in the monitoring of Treasury programs,” Adeyemo said. “We must maintain appropriate mechanisms to regularly evaluate our compliance strategies, systems, and selection tools.”
In addition to these core principles, Treasury Department bureaus and offices are being called upon to review existing communication, compliance, and enforcement policies and procedures; consult with key stakeholders on those policies; develop methods to regularly test compliance and enforcement systems; and report semi-annually to the deputy secretary on their implementation efforts. 
Jaclyn Jaeger is a contributing editor at Compliance Chief 360° and a freelance business writer based in Manchester, New Hampshire.