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Top Compliance Leadership Skills for the Wild Wild West that is Coming – Part 3, Humor

This week, the world changed when Donald Trump was inaugurated as the 47th President of the US. Indeed, the only thing I can guarantee with complete certainty is change. I was therefore intrigued by Melissa Swift’s recent MIT Sloan Business Review article, “Three Nonnegotiable Leadership Skills for 2025.” In this week of change, I cannot think of a more prescient article for the compliance professional.

I adapted Swift’s three critical leadership skills for the compliance professional: fairness, curiosity, and a sense of humor. In this concluding blog post of this three-part series, I will explore how compliance leaders can develop and leverage these skills to strengthen their programs and inspire their teams throughout the tumultuous next four years using humor.

Your Saving Grace: Sense of Humor

As Ronnie Feldman continually reminds us, do not be “Debbie Downer,” or as I would say, do not be Dr. No from the Land of No. In some ways, Ronnie focuses on attitude, while I tend to focus a bit more on the message. However, you might look at it. Between audits, policy rollouts, regulatory updates, and managing the risk employees inevitably want to take, a sense of humor is a powerful tool for staying grounded and maintaining perspective.

It is important to note that you need the right kind of humor for compliance leadership. This does not mean you should become the office comedian. Instead, humor in compliance leadership is about finding light in challenging situations and encouraging your team to do the same. For example, after navigating a tough audit and telling your team, “Well, we survived—and I didn’t even need to bribe anyone with donuts this time!” That simple quip can diffuse tension and signal that it’s okay to exhale.

The humor in your attitude and what you can bring to your customer base. Humor can reduce stress. Compliance work often operates under tight deadlines, high stakes, and relentless scrutiny. This pressure can weigh heavily on teams, leading to burnout and diminishing productivity. A leader who uses humor to lighten the mood helps to ease stress, making the workplace feel less like a pressure cooker and more like a place of collaboration and problem-solving.

Humor can help to build relationships, as compliance leaders often face the challenge of appearing approachable while maintaining authority. Humor humanizes leaders, making them more relatable and easier to connect with. When you can laugh at yourself or acknowledge the absurdities of compliance work with a smile, your team feels more comfortable sharing ideas, asking questions, and raising concerns.

Humor can make you a better compliance officer. When people are less stressed, their creativity and problem-solving abilities improve. Humor reduces the brain’s fight-or-flight response, allowing for more thoughtful and innovative approaches to challenges. A leader who fosters an environment where it’s okay to laugh at setbacks or unexpected hurdles creates a culture where solutions flow more freely. For example, if a compliance initiative hits a snag, a leader who can frame it with humor, “Okay, so maybe this isn’t Plan A…or Plan B…but I have high hopes for Plan C!” encourages the team to stay flexible and keep brainstorming.

The Right Kind of Humor for Compliance Leadership 

Humor in compliance leadership is not about cracking jokes or becoming the office comedian. Instead, it is about using levity strategically to foster positivity and resilience. Some key principles are as follows:

  1. Diffuse Tension, Don’t Deflect Responsibility. A well-timed, self-deprecating comment can make you more relatable, but humor should never be used to deflect accountability. For example, if a compliance policy rollout faces delays, saying, “Looks like my time management skills could use some compliance training of their own!” shows humility without shirking responsibility.
  2. Celebrate Compliance Wins Playfully. Recognizing team achievements doesn’t have to be dry or overly formal. Use humor to make celebrations memorable. Consider giving out light-hearted awards like “Most Persistent Policy Enforcer” or decorating the office with “Mission Accomplished” banners after a successful audit. These small gestures show appreciation while keeping the mood light.
  3. Maintain Perspective. Compliance is serious work, but that does not mean you must take every situation or yourself too seriously. Laughing at the absurdities of navigating complex regulations or managing a mountain of policies reminds your team that, while the work is important, it’s okay to have a sense of humor about the challenges.

Applying Humor to Compliance Challenges in 2025

Humor is not simply a feel-good tool. It can be strategically applied to some of the most pressing challenges compliance professionals face in 2025.

  • Building Ethical Cultures Amid Workforce Discontent

With employee engagement at a low and workplace polarization on the rise, leaders must model fairness and transparency to rebuild trust. Humor can complement these efforts by making leaders more relatable and approachable. For example, during a town hall on compliance updates, opening with a light joke about the complexity of the latest regulations, “I think the word paid the lawyers who wrote this!” can put employees at ease and make the session more engaging.

  • Navigating Emerging Risks

As AI, ESG, and privacy dominate the compliance agenda, staying ahead of these risks requires proactive engagement and innovation. Humor can make daunting challenges feel more manageable. For example, when introducing training on AI ethics, a leader might quip, “Don’t worry, our goal is to make sure the robots are working for us, not the other way around!” This approach encourages curiosity and open-mindedness.

  • Managing Regulatory Fatigue

As regulations grow more complex, compliance fatigue becomes a real risk for teams. Or, as the Trump Administration whipsaws the business communities with new mandates morning, noon, and night, business and compliance leaders who inject humor into routine tasks, like creating a fun, interactive quiz for compliance training or adding light-hearted captions to a policy presentation, can make the work feel less monotonous. A leader who acknowledges the challenges with humor, such as “Regulatory updates: the gift that keeps on giving!” helps your compliance team feel seen and supported, even as they tackle challenging workloads.

How to Integrate Humor Into Your Leadership Style

If you’re ready to harness the power of humor in your compliance leadership, here are some practical tips:

  1. Know Your Audience. Tailor your humor to your team’s preferences and sensitivities. Avoid sarcasm or jokes that could be misinterpreted.
  2. Start Small. During meetings, test the waters with light-hearted comments or anecdotes. Observe how your team responds and adjust accordingly.
  3. Encourage Teamwide Levity. Create a culture where humor is welcomed. For example, designate a “fun committee” to plan occasional light-hearted activities, like a compliance trivia game or themed office decorations.
  4. Keep It Contextual. Use humor to enhance, not detract from, the seriousness of compliance work. Acknowledge the gravity of issues like regulatory violations while using humor to build resilience.

The Bottom Line: Humor as a Leadership Strength

In 2025, compliance leaders will face mounting challenges, from increasing regulatory complexity to employee disengagement to a more focused enforcement presence in some verticals. A sense of humor can be your secret weapon for gracefully and effectively navigating these difficulties.

By reducing stress, building connections, and fostering creative problem-solving, humor enhances your leadership and the overall resilience of your compliance team. Remember, humor doesn’t diminish the importance of your work; it underscores your ability to lead with empathy, perspective, and authenticity.

In the high-stakes world of compliance, laughter truly is a saving grace. So, the next time you find yourself knee-deep in regulatory updates or preparing for a strict audit, don’t forget to take a moment to smile, laugh, and remind your team that even in the most serious work, a little levity goes a long way.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 21 – Managing 3rd Parties

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

On Day 21 of our series, we dive into the essential strategies for managing third-party relationships in a compliance program. We consider the significance of a structured and strategic approach in handling third parties to mitigate anti-corruption risks. As companies mature, the operationalization of compliance through third-party management becomes crucial. Key areas explored include the importance of dual and diversified sourcing, monitoring subcontractors, legal protections, and financial stability checks. Additionally, we cover the necessity of integrating performance-based compensation and regular auditing to uphold compliance standards. Join us tomorrow as we explore levels of due diligence on Day 22.

Key highlights:

  • Strategic Approach to Third-Party Relationships
  • Auditing and Ongoing Management
  • Key Takeaways

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

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Innovation in Compliance

Innovation in Compliance – Navigating Accounting and Compliance with Mike Whitmire

Innovation comes in many areas, and compliance professionals must be ready to embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox visits Mike Whitmire, Co-founder & CEO at FloQast, on his journey in accounting and compliance.

In this episode, Tom is in a riveting conversation with Mike Whitmire, Co-founder & CEO at FloQast. They dive into Mike’s professional journey, starting from his early days at Ernst & Young, navigating the complexities of Sarbanes-Oxley (SOX) compliance, and eventually founding FloQast. Mike shares his firsthand experiences with the challenges in accounting and compliance, such as the talent gap and behavior change within organizations, and explains how FloQast’s closed management and compliance software addresses these issues. The discussion deeply delves into risk orchestration and its critical role in modern compliance strategies.

Additionally, Mike provides insights into his passion for podcasting and touches on his book, ‘Shift Happens,’ co-authored to highlight the rise of the operational accountant. The episode wraps up with a focus on FloQast’s innovative solutions that integrate daily accounting tasks with compliance requirements, thus simplifying processes for finance professionals. Tune in to hear how a common pain point in the accounting world led to the creation of a transformative software solution.

Key highlights:

  • Challenges in Accounting and Compliance
  • Risk Orchestration and Compliance
  • Mike’s Podcast and Book

Resources:

Mike Whitmire on LinkedIn

FloQast

Purchase Shift Happens on Amazon.com.

Tom Fox

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Daily Compliance News

Daily Compliance News: January 21, 2025, The Not Real Work Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • WFH is not ‘real work’. (BBC)
  • More conflict mineral allegations against Apple from DRC. (FT)
  • Trash compliance—it’s a thing. (Gothamist)
  • Trump accuses the FBI of ‘corruption’ in closing its DEI office. (Forbes)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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SBR - Authors' Podcast

SBR – Author’s Podcast – Exploring the Future of Work, Ethics, and Compliance with Kelly Monahan, Part 2

Welcome to the Sunday Book Review, The Authors Podcast! Host Tom Fox visits with authors in the compliance arena and beyond in this Podcast Series. Today, Tom is joined by his good friend and colleague, Earnie Broughton (Earnie from Boerne), to visit with Dr. Kelly Monahan, co-author of the soon-to-be-released book Essential: How Distributed Teams, Generative AI, and Global Shifts are Creating a New Human-Powered Leader.  (Co-authored with Dr. Christie Smith) We three had such good fun that we went on for nearly an hour, so we have broken up the interview into two podcasts. If you have not checked out our first episode, you can do so by clicking here.

In Part 2, we deeply dive into effective communication tools for conveying corporate values to diverse workplace groups, emphasizing tailored training and gamification. Kelly highlights the importance of engaging, behavior-reinforcing communications through storytelling and public recognition systems. Emphasizing intrinsic motivation over financial incentives, Kelly draws on behavioral economics and the importance of fostering an environment of curiosity and context awareness for leadership roles. The discussion also addresses the nuances of generational differences in the workforce and the importance of diversity, equity, inclusion (DEI), and ESG initiatives for long-term organizational sustainability. Compliance professionals are encouraged to stay ahead of AI developments and promote positive behaviors to align with evolving business and ethical standards.

Key highlights:

  • Effective Communication Tools for Corporate Values
  • Future of Leadership in the Age of AI
  • Suspending Self-Interest and Cultivating Curiosity
  • Importance of Context in Ethical Decision-Making
  • Generational Differences in the Workforce
  • Role of Ethics and Compliance Professionals

Resources:

The Essential Website

Pre-Order Essential: How Distributed Teams, Generative AI, and Global Shifts are Creating a New Human-Powered Leader on Amazon.com

Kelly Monahan on LinkedIn

Earnie Boughton On LinkedIn

Tom Fox

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Blog

Top Compliance Leadership Skills for the Wild Wild West that is Coming – Part 2, Curiosity

This week, Donald Trump was inaugurated as the 47th President of the United States. I can only say with complete certainty that the world of compliance will never be the same. Trump not only promises tariffs and sanctions against America’s enemies and competitors but also promises them against America’s friends. His views on the Foreign Corrupt Practices Act (FCPA) are well known (‘a horrible law’), and so are his views on bribery.

He may well be the first President to employ the FCPA as a tactical weapon against companies from countries that are not only the US’s enemies and competitors but also our allies. This is nothing to say about how he will direct the Department of Justice to use the Foreign Extortion Prevention Act (FEPA) against our enemies, competitors, and allies. So prepare for the Wild West of corporate compliance for the next four years.

As compliance professionals face this miasma in 2025, compliance leadership skills will be more critical than ever. With these new, renewed, and mounting regulatory pressures, declining employee engagement, and intensifying demand for ethical corporate governance, the role of compliance leaders has never been more pivotal or challenging.

This week, I am looking at three leadership skills for the Chief Compliance Officer (CCO), compliance professional, or compliance practitioner to focus on for this sea change in compliance. One faces outward, one faces inward, and the third relates to your attitude. They are (1) fairness, (2) curiosity, and (3) a sense of humor. These three skills will enhance your team’s effectiveness and strengthen your organization’s overall compliance posture. Yesterday, we considered fairness. Today, we look at the curiosity of the compliance professional.

Curiosity: Your Secret Weapon for Compliance Growth 

From my experience, curiosity is a game-changer in compliance. Indeed, in the initial Radical Compliance podcast, Matt Kelly interviewed Hui Chen about the original (2017) Evaluation of Corporate Compliance Programs; she said it was designed to get compliance professionals and CCOs to ask questions about their compliance programs.

Besides the Trump Administration, in 2025, compliance programs will face emerging challenges such as AI ethics, ESG requirements, and new data privacy laws. Curiosity enables compliance leaders to stay ahead of these trends, fostering innovation and adaptability in their programs. Curious leaders break free from silos, seek new knowledge, and inspire their teams to think creatively. This mindset is critical for identifying risks and opportunities in an unpredictable regulatory environment.

Curiosity drives innovation, sharpens problem-solving skills, and helps compliance officers identify risks and opportunities others may overlook. But how can compliance professionals actively cultivate curiosity in themselves and their teams? Here’s a roadmap to help you stay informed, ask better questions, and fill critical knowledge gaps.

Stay Informed on Industry Trends 

Regulatory landscapes are shifting faster than ever, with new challenges arising in artificial intelligence (AI), environmental, social, and governance (ESG) standards, and data privacy. Compliance professionals must proactively stay informed about these trends to keep their programs agile and relevant. Indeed, every Deferred Prosecution (DPA) includes language mandating awareness of other businesses in their industry and any compliance developments.

What are some of the action steps a compliance professional or CCO can take? If you are reading this blog post, it is an excellent first step. You can listen to one or more of the 50 podcasts on the Compliance Podcast Network. Both steps will put you on the cutting edge of the nuts and bolts of compliance. For topical compliance news and analysis, you can read well-known commentators such as Matt Kelly on Radical Compliance. You can read industry publications like Compliance Week or law firm or consulting firm newsletters on topical compliance issues. Focus on emerging areas like AI ethics, ESG enforcement actions, and updates to GDPR or other privacy frameworks.

Attending webinars and conferences are excellent opportunities to hear from industry leaders, regulators, and peers. These conferences include Ethisphere and Compliance Week in the spring and SCCE and ACI in the fall. These events provide real-time insights and practical strategies for addressing emerging risks. When you attend such events, you can often garner as much information by networking with your peers. You can also join professional organizations, such as SEEC, ACFE, ECI, and others, which often have online forums to exchange knowledge and share best practices with other compliance professionals.

By staying informed, you can anticipate changes before they disrupt your organization and position yourself as a forward-thinking compliance leader.

Ask Better Questions 

Compliance professionals are often tasked with identifying risks and making decisions under uncertainty. The quality of the questions you ask determines the depth of your understanding and the effectiveness of your solutions. Traditional compliance questions like “What’s the risk here?” are essential but can be limiting. To foster curiosity, you need to dig deeper and challenge assumptions.

What are some examples of better questions you can ask? Start with such basics as “What assumptions are we making, and how can we test them?” This question helps uncover blind spots in risk assessments or compliance strategies. Follow up with questions like “How does this risk evolve?” Understanding the lifecycle of a risk can help you develop proactive mitigation strategies. Always add this query to your repertoire: “What can we learn from other industries?” Exploring how different sectors handle similar challenges can inspire innovative solutions in your company.

You should work to apply all of this in your everyday compliance work. Start by encouraging your team to approach problems from multiple angles. Take your risk assessment, where you can consider not just the likelihood and impact of a risk but also the assumptions underlying those ratings. This mindset shift leads to more robust and effective compliance strategies.

 Fill Knowledge Gaps 

In the compliance field, the more you know, the more you realize how much you still need to learn. Recognizing and addressing knowledge gaps is a critical skill for any compliance professional. Think about compliance issues in some of the following ways: Reflect on your recent projects or decisions. Consider if there were times when you felt unsure or relied heavily on external experts. Keep track of emerging topics where you only have surface-level knowledge, such as ESG reporting requirements or AI regulations. Finally, do not be afraid to ask your team for feedback. They may identify areas where additional expertise could strengthen the program.

Encourage Curiosity in Your Team

Curiosity is not simply a personal trait but a cultural value that compliance leaders can cultivate within their teams. A curious team is more likely to challenge assumptions, identify risks early, and propose creative solutions. You do not have to send your team to conferences to foster curiosity. You can do that yourself by creating opportunities for cross-functional in-house learning. Invite experts from other departments, such as cybersecurity, ESG, or finance, to share insights during compliance meetings. This not only broadens your team’s knowledge but also strengthens cross-departmental collaboration.

Encourage “What If” scenarios by asking your team to imagine hypothetical scenarios and explore how they would address them. Such as, “What if we faced a cyber breach tomorrow?” or “What if a supplier violated ESG standards?” It can be a perfect starting point for you and your entire team. Finally, celebrate curiosity by recognizing and rewarding team members who ask insightful questions, propose innovative ideas, or learn about emerging risks. By embedding curiosity into your team’s culture, you empower them to think critically and proactively, enhancing the overall effectiveness of your compliance program.

Curiosity is a powerful tool that enhances professional growth and strengthens compliance programs’ resilience and adaptability. In 2025 and beyond, compliance leaders who embrace curiosity will be best positioned to navigate uncertainty, address emerging risks, and lead their organizations confidently.

Join us tomorrow as we explain why having a sense of humor may be the most important skill for surviving the new administration’s inevitable chaos.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 20 – Third-Party Risk Management Process

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

On Day 20, we delve into the third-party risk management process, a crucial aspect of corporate compliance under the FCPA. Third parties continue to pose the highest risk, necessitating an integrated and operational approach throughout the company. The episode outlines the five essential steps in the third-party risk management life cycle, as mandated by the DOJ in the 2020 FCPA Resource Guide. These steps include business justification, third-party questionnaires, due diligence, compliance terms and conditions, and post-contract management and oversight. Each step is explored in detail, emphasizing the importance of documenting business cases, performing thorough due diligence, and maintaining diligent oversight to mitigate potential FCPA violations. Key takeaways include the necessity of using the full five-step process, involving business development and ensuring all steps are operationalized with business unit representatives. Join us tomorrow for Day 21 to discuss managing your third parties.

Key highlights:

  • Introduction to Third Party Risk Management
  • The Five Steps of Third-Party Risk Management
  • Key Takeaways

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

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The Ethics Experts

Episode 191 – Todd Haugh

In this episode of The Ethics Experts, Nick welcomes Todd Haugh.

Todd Haugh is an Associate Professor of Business Law and Ethics and the Arthur M. Weimer Faculty Fellow in Business Law at Indiana University’s Kelley School of Business, where he also serves as the Director of the Institute for Corporate Governance. His scholarship focuses on white-collar and corporate crime, business and behavioral ethics, and federal sentencing policy. His work has appeared in top law and business journals, including the Northwestern University Law Review, Notre Dame Law Review, Vanderbilt Law Review, and the MIT-Sloan Management Review.

Todd Haugh on LinkedIn
Todd’s personal website

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Corruption, Crime and Compliance

2024 DOJ and OFAC Sanctions Enforcement and Compliance Review

How will your company withstand the heat of aggressive sanctions enforcement? Are you ready for the DOJ’s new priorities and OFAC’s expanding reach in 2025? In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into the major sanctions enforcement trends from 2024 and the road ahead under the new Trump administration. From record-breaking DOJ prosecutions to OFAC’s innovative enforcement approaches, Michael explains how sanctions compliance is more critical than ever. He highlights the year’s biggest cases, uncovers common pitfalls that led to costly penalties, and outlines how businesses can navigate shifting regulatory priorities. Whether integrating compliance in M&A or addressing the risks of evolving China and Iran sanctions, this episode delivers actionable insights for staying ahead of enforcement risks.

You’ll hear him discuss:

  • The DOJ’s record-breaking prosecution of 70 individuals in 2024 and predictions for a surge in enforcement in 2025.
  • OFAC’s evolving enforcement strategy, including secondary sanctions tied to U.S. dollar transactions and new compliance commitments.
  • Key lessons from major enforcement actions like SCG Plastics, Aotech, and MondoTV, which paid millions for sanctions violations.
  • The consequences of neglecting sanctions compliance during mergers and acquisitions, including inherited liabilities and enforcement risks.
  • Predictions for heightened scrutiny on trade with China, aggressive tariffs, and evolving Iran sanctions under the new administration.
  • How emerging issues like advanced computing, AI, and dual-use technologies are becoming focal points for sanctions enforcement.
  • The role of voluntary self-disclosure in mitigating penalties, with examples of companies that uncovered and corrected compliance gaps.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Blog

Top Compliance Leadership Skills for the Wild Wild West that is Coming – Part 1, Fairness

Today, Donald Trump will be inaugurated as the 47th President of the United States. I can only say with complete certainty that the world of compliance will never be the same after today. Trump promises tariffs and sanctions against America’s enemies, competitors, and friends. His views on the Foreign Corrupt Practices Act (FCPA) are well known (‘a horrible law’), and so are his views on bribery.

He may well be the first President to employ the FCPA as a weapon against companies from countries that are not only the US’s enemies and competitors but also our allies. This is nothing to say about how he will direct the Department of Justice to use the Foreign Extortion Prevention Act (FEPA) against our enemies, competitors, and allies. So get ready for the Wild West of corporate compliance for the next four years.

As compliance professionals face this miasma in 2025, compliance leadership skills will be more critical than ever. With these new, renewed, and mounting regulatory pressures, declining employee engagement, and intensifying demand for ethical corporate governance, the role of compliance leaders has never been more pivotal or challenging.

To navigate the first part of this Wild West, I propose three leadership skills for the Chief Compliance Officer (CCO), compliance professional, or compliance practitioner to focus on. One faces outward, one faces inward, and the third relates to your attitude. They are (1) fairness, (2) curiosity, and (3) a sense of humor. These three skills will enhance your team’s effectiveness and strengthen your organization’s overall compliance posture.

Fairness: The Cornerstone of Compliance Leadership

Fairness is the bedrock of a strong compliance culture. Employees who perceive their leaders as fair are likelier to adhere to policies, report concerns, and contribute to an ethical workplace. With 70% of workers dissatisfied with their pay and disengagement on the rise, fairness is no longer optional; it is essential. You only need to conference the entire controversy around Return to the Office (RTO) at JP Morgan when, as the Wall Street Journal reported, the company disabled its internal chat function because of the plethora of negative comments on the full implementation of RTO. Talk about not wanting to hear what is on your employees’ collective minds.

Fairness extends beyond legal compliance into the realm of interpersonal relationships. For compliance leaders, this means:

1. Relationship Justice-Treating employees with professionalism, dignity, and respect

Relationship justice is the foundation of trust in any organization and a critical component of compliance leadership. It involves treating employees as valued contributors, respecting them, and maintaining professionalism. Leaders who model relationship justice foster an environment where employees feel psychologically safe to raise concerns, share ideas, and report potential misconduct. For compliance professionals, this means actively listening to employee feedback, addressing grievances promptly, and avoiding behaviors that could be perceived as favoritism or bias. Consistently demonstrating respect and dignity reinforces ethical culture and strengthens employee morale and engagement, making them more likely to align with compliance initiatives.

2. Task Justice- Ensuring decisions are transparent and consistent.

Task justice focuses on the “how” of leadership—how decisions are made, communicated, and executed. Transparency is key to task justice; employees should understand the rationale behind decisions, especially when they affect their roles, responsibilities, or compensation. Consistency is equally important, as arbitrary or unpredictable decision-making undermines trust and can lead to perceptions of unfairness. Compliance leaders can implement task justice by using structured frameworks for decision-making, such as compliance risk matrices, and by documenting the process for policy updates or disciplinary actions. Clear communication of decisions and opportunities for employees to ask questions or provide feedback ensures that everyone feels included and informed, reducing resentment and fostering collaboration.

3. Distributive Justice – Aligning rewards with individual contributions

Distributive justice ensures that rewards, recognition, and outcomes are proportionate to the effort and contributions of individual employees. This dimension of fairness requires leaders to assess performance objectively and ensure that rewards—whether promotions, bonuses, or simple recognition—are distributed equitably. For compliance professionals, distributive justice can manifest in recognizing team members’ contributions to audits, investigations, or training programs. Leaders should avoid blanket recognition that overlooks individual effort and tailor rewards to highlight specific accomplishments. Employees who feel their contributions are valued and acknowledged are more likely to remain engaged, motivated, and committed to compliance goals. Ultimately, distributive justice reinforces the message that ethical behavior and hard work are consistently rewarded.

The CCO is pivotal in embedding fairness within the compliance program and the broader corporate culture. The DOJ refers to this as Institutional Justice and Fairness in the 2024 Evaluation of Corporate Compliance Programs. Whatever you (or the DOJ) might call this, the CCO must prioritize transparency, consistency, and respect across all compliance and cultural touchpoints to achieve this.

First, fairness starts with transparent processes in the compliance program. The CCO should establish clear protocols for investigations, audits, and disciplinary actions, ensuring employees understand the steps and criteria used in decision-making. The CCO can reduce bias and promote consistency by leveraging tools such as decision matrices or documented frameworks. Regular communication about compliance updates, policy changes, and enforcement actions reinforces transparency and builds trust.

Second, fairness in corporate culture is achieved through relationship-building and recognition. The CCO should foster open dialogue by creating channels for employees to voice concerns without fear of retaliation. Training programs emphasizing fairness—such as workshops on unconscious bias or ethical leadership—can cultivate a more respectful workplace. The CCO must ensure that ethical behavior and contributions to compliance efforts are consistently acknowledged and rewarded.

Ultimately, by modeling fairness in leadership and weaving it into compliance processes and cultural practices, the CCO sets the standard for ethical behavior, fostering employee trust and long-term organizational integrity.

Join us tomorrow to explore curiosity and the CCO/compliance professional.