Full Disclosure: Power to the Process Owners

John Wheeler's previous title -- relationship manager -- also describes his current compliance mission with SunTrust Banks Inc.

As senior vice president of financial reporting risk management, Wheeler is responsible for elevating the Atlanta-based, $1.7 billion bank's Sarbanes-Oxley compliance program from "sustainable" status to ongoing "improvement" mode. To execute that board-level mandate, Wheeler educates and empowers process owners to understand, monitor and improve financial-reporting internal controls.

"To do this successfully, you have to embed the compliance process within each of the company's businesses," says Wheeler. For example, formal control review meetings are now conducted quarterly among a SunTrust division head, the risk manager assigned to that division, and the "owners" of internal controls within the division to ensure that the controls are operating effectively. Another division includes the detailed control test results within a process/control owners' area as a formal portion of the annual performance management review document.  

The organizational structures, technologies and processes that fuel SunTrust's compliance empowerment effort provide useful guidance for companies striving to sharpen their compliance efforts and to integrate compliance with risk management and governance processes.