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The Personalization Imperative: Lessons for Compliance Professionals 

Personalization has emerged as a transformative force in modern business and modern communications. Marketing is no longer about addressing a customer by name in an email but delivering tailored experiences at scale, powered by artificial intelligence (AI) and data-driven insights. In a recent article in the Harvard Business Review, entitled Personalization Done Right, authors Mark Abraham and David Edelman wrote about how companies like SonderMind, Spotify, and Sweetgreen lead the charge, using innovative personalization strategies to create value and delight their customers. However, personalization presents some interesting opportunities for compliance professionals to balance innovation with regulatory obligations, ethical considerations, and data privacy concerns.

Today, I want to examine the lessons that compliance professionals can draw from the personalization strategies outlined in the BCG Personalization Index. I will focus on maintaining compliance while enabling businesses to leverage personalization as a competitive advantage. 

The Five Promises of Personalization 

Personalization leaders succeed by fulfilling five implicit promises to their customers:

  1. Empower Me – Make my experience seamless and intuitive.
  2. Know Me – Use my data responsibly to understand my needs.
  3. Reach Me – Engage with me at the right time, on the right channel.
  4. Show Me – Provide relevant, tailored content.
  5. Delight Me – Continuously improve my experience through innovation.

Each of these promises presents opportunities and risks that compliance professionals must navigate.

  • Empower Me: Enhancing the Customer Journey 

Businesses like SonderMind demonstrate how personalization can empower users. SonderMind’s mental wellness app analyzes individual data to suggest actionable steps, such as meditation or journaling, and arm therapists with anonymized insights to optimize treatment plans. This results in better outcomes for patients and reduced costs for insurers.

For the compliance professional empowering employees (the customers of compliance), Personalization leaders start by asking: How can I make the employee’s experience better by personalizing it? For a compliance professional, this means understanding an employee’s unique needs at every step of their journey and deciding how personalization can best help them. The Department of Justice calls this ‘targeted’ training and communications.

  • Know Me: Building Trust Through Data 

The authors point to Sweetgreen, “a newcomer to the restaurant business relative to the largest chains,” which illustrates this point well. Right from its start, in 2007, it invested in building digital customer relationships. It launched a mobile app in 2013, ahead of many large restaurant chains, and progressively added features such as mobile ordering, delivery, personalized offers and challenges, and a loyalty program to drive digital engagement.

Here, the compliance professional can not only stream compliance communications more efficiently but also use those same communications to build relationships and trust with your employees. Obviously, this is directly in the compliance wheelhouse, as data governance is paramount. Compliance teams must oversee the integration of customer data across systems, ensuring it is accurate, secure, and used in accordance with stated policies.

  • Reach Me: Engaging Responsibly 

Having the data to know the customer is not enough. Your organization must use AI to identify triggers to reach out, such as when a customer browses online or inquires. Then, orchestrate touches across channels and use smart frequency management to ensure their touches are coordinated and not overwhelming. The authors pointed to Cisco, whom they said is “a personalization leader. Its sales team knows whom to contact, when, and about what and comes armed with relevant content and demos. Because Cisco’s sales and marketing teams are closely linked, customers get coordinated exposure to content that supports their needs and that opens up sales dialogues.”

This is precisely how compliance professionals should think about targeted and effective training and communications. This type of coordinated approach, based on employee needs or questions, can pay off with big compliance benefits. Overreach will turn off employees if the communications are bad, useless, and overwhelming. You do not want to cause ‘compliance communication fatigue.’ Compliance professionals must monitor how AI models are recommended, ensuring they align with legal standards and ethical norms.

  • Show Me: Tailoring Content 

Pandora shows how generative AI can create personalized content, reducing production times and improving engagement. The authors noted, “The global jewelry brand Pandora thrives by sparking customer interest with inspirational content. As part of its strategy, it uses AI-generated content to tailor its messaging to each customer and cut cycle times for certain types of content creation from 12 to 14 months to a mere 10 days. The company learned that personalizing the background and model image for each individual—and coordinating how the customer sees those images across emails, websites, and other ads—substantially improved conversion rates.”

This speaks to the DOJ mandate for tailored training. However, you should also consider the business ethics message you can give customers. It can be similar to that of other companies that have gotten into FCPA or other regulatory trouble, celebrating your employees who have done the right thing or consistent messages from your CEO or senior executive about doing business ethically and in compliance.

  • Delight Me: Driving Continuous Improvement 

Personalization leaders adopt agile working methods to accelerate testing and learning, improving the intelligence behind each customer interaction. Companies like DoorDash epitomize the “delight me” promise by running hundreds of micro-experiments to refine their personalization efforts. This agile approach enables rapid innovation but requires robust oversight to ensure compliance with regulations.

Continuous improvement is directly in the wheelhouse of compliance. You should be able to take the feedback you receive from your employees and incorporate that information into your future communications. Even more exciting is the opportunity to have employees individually improve their ways of doing business ethically and in compliance. Compliance professionals should collaborate with product teams to ensure experiments respect privacy laws and customer expectations.

Key Lessons for Compliance Professionals 

  1. Embrace the Role of Enabler. Compliance should not be a roadblock to innovation. Instead, compliance professionals can enable responsible personalization by embedding themselves in cross-functional teams and offering solutions aligning with business goals and regulatory requirements.
  2. Prioritize Data Privacy. As personalization relies heavily on customer data, compliance teams must prioritize data privacy and security. This includes ensuring compliance with global regulations like GDPR, CCPA, and industry-specific standards.
  3. Establish AI Governance. AI is a cornerstone of modern personalization. Compliance professionals must develop and enforce governance frameworks to ensure AI is used ethically and transparently.
  4. Foster a Culture of Transparency. Customers are more likely to trust companies that are upfront about how their data is used. Compliance teams should advocate for clear and accessible privacy policies.
  5. Monitor Regulatory Trends. Personalization efforts are subject to evolving regulations. Compliance professionals must stay informed about changes in data privacy, AI ethics, and advertising standards to guide their organizations effectively.

The Future of Compliance is Personalization 

The rise of personalization presents compliance professionals with a unique opportunity to lead. By ensuring that personalization efforts are ethical, transparent, and compliant, they can help their organizations build trust, drive innovation, and achieve sustainable growth.

As the BCG Personalization Index shows, companies that excel in personalization delight their customers and create significant business value. The same applies to a corporate compliance function and its customers, IE., employees. Compliance professionals are essential to realizing this potential, ensuring businesses can innovate responsibly and thrive in an increasingly competitive landscape.

Compliance is not simply about preventing wrongdoing but enabling your organization to do things correctly. Personalization of compliance is no exception. Compliance professionals should embrace this opportunity and take charge of a future where personalization and compliance go hand in hand.

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Compliance Tip of the Day

Compliance Tip of the Day: Skills for Compliance Professionals into 2030 and Beyond

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we consider the five skills every compliance professional should develop to take the next step into 2025, 2030, and beyond in the compliance field. They are: (1) Adapt to thrive; (2) Be creative; (3) Develop emotional intelligence; (4) Become tech-savvy; and (5) Build your personal brand.

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Blog

Alexander Cotoia on Continuous Growth and Development: The Key to Success in Compliance

I recently had the opportunity to visit with folks from Diligent we look down the road at key issues in 2024 in a podcast series, sponsored by Diligent, entitled Compliance professionals adapting to change: Industries, Regulations, and Beyond. I was able to chat with Nicolas Latham, Renee Murphy, Jessica Czeczuga, Yee Chow, and Alexander Cotoia. Over this series, we discussed compliant communications in regulated industries, managing conflicts of interest at the Board level, the Board’s role in compliance training and communications, navigating the current ESG landscape and professional growth and mentorship in compliance. In this concluding Post 5, we discuss professional development and mentorship for compliance professionals with Alexander Cotoia.

Continuous professional development is crucial for compliance professionals, especially those in leadership positions. In a dynamic regulatory environment with expanding responsibilities, staying up to date is essential. Compliance professionals must not only understand domestic laws but also international regulations, such as the EU’s Corporate Sustainability Directive (CS 3D). This extraterritorial impact of legislation emphasizes the need for continuous education to address these developments.

Mentorship plays a vital role in the professional growth of compliance professionals. Often, the focus is on the development of hard skills, but soft skills like communication, collaboration, and relationship-building are equally important. Compliance professionals need to be able to speak the language of different stakeholders within the corporate world, such as CFOs or CISOs. Obtaining a working vocabulary in a corporate context is crucial for effective collaboration and building positive rapport with operational functions.

Fortunately, there are numerous resources available for continuous professional development. Platforms like LinkedIn, Coursera, and Harvard Business School online offer courses that focus on soft skills, negotiation, building relationships, and strategic planning. These courses provide compliance professionals with the necessary tools to excel in their roles. Taking courses outside the realm of compliance, such as business fundamentals, can also enhance their understanding of critical business concepts.

Thought leadership is another valuable tool for continuous learning and professional growth. Writing blogs and articles not only showcases expertise but also forces compliance professionals to learn and digest new information. Engaging in thought leadership allows compliance professionals to stay informed, expand their knowledge, and contribute to the compliance community. It also opens doors for networking and potential collaboration opportunities.

The compliance profession offers a challenging yet rewarding career path. It provides opportunities for professional and financial growth. For students considering a career in compliance, mentorship and continuous learning are emphasized as essential elements. Starting in compliance can lay a solid foundation for future success.

Balancing the tradeoffs involved in continuous professional development for compliance professionals can be challenging. It requires finding the right mix of hard and soft skills, staying updated on regulatory changes, and actively engaging in thought leadership. Compliance professionals must consider the impact of their decisions on their own professional growth and the organizations they serve.

In conclusion, continuous professional development is crucial for compliance professionals, particularly those in leadership roles. The dynamic regulatory environment and expanding responsibilities necessitate staying updated on both domestic and international laws. Developing soft skills, obtaining a working vocabulary in a corporate context, and engaging in thought leadership are essential for success in the compliance profession. Mentorship and continuous learning are emphasized as critical elements for professional growth. Compliance professionals must strive to find the right balance and make informed decisions that benefit their careers and the organizations they serve.

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com

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31 Days to More Effective Compliance Programs

One Month to Better Reporting and Investigations – Preparing for the Investigation

Under Part 1, Section D. Confidential Reporting Structure and Investigation Process stated in part, Properly Scoped Investigation by Qualified Personnel –What steps does the company take to ensure investigations are independent, objective, appropriately conducted, and properly documented? How does the company determine who should conduct research, and who makes that determination? These questions were presaged by the DOJ’s 2015 Yates Memo and the 2016 FCPA Pilot Program. The pressure on every CCO and company to get an investigation done quickly, efficiently and, most importantly, right is even greater now.
Jonathan Marks began by cautioning that when considering any well-run internal investigation, a CCO must be cognizant of the strictures laid out in the Evaluation. It all begins with who in-house is looking at the complaint and does the CCO, compliance practitioner, or legal team have the skills and capabilities to handle the matter which has arisen. Obviously, if there are esoteric accounting issues or significant internal control workarounds and overrides, a CCO may not have the skills to really understand all the issues. Similarly, if the matter is a global FCPA or equivalent bribery and corruption matter, Marks related, these “come in different flavors, and because they come in different flavors you may not have the skills or capabilities to do an investigation that would take place in say Brazil or Russia or China or India.”

Three key takeaways:

  1. Always remember your ultimate audience may be the government.
  2. You must understand both the business environment and extended business enterprise.
  3. Communication and collaboration in any investigation are critical so you should begin early and continue to do so throughout the investigation.
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Blog

Tribute to Cormac McCarthy-Lessons for the Compliance Professional

Cormac McCarthy died last week. According to his New York Times (NYT) obituary, he was “the formidable and reclusive writer of Appalachia and the American Southwest, whose raggedly ornate early novels about misfits and grotesques gave way to the lush taciturnity of “All the Pretty Horses” and the apocalyptic minimalism of “The Road,” died on Tuesday at his home in Santa Fe, N.M. He was 89.” I came to McCarthy through his work All The Pretty Horses and it was one of the seminal books I have ever read. The only book I can compare it to is Now Let’s Us Praise Famous Men by James Agee and photographer Walker Evans. (Evan’s photos are as spectacular and as equally famous as Agee’s prose.) So today, as my tribute to McCarty, I wanted to take a deep dive into All The Pretty Horses and mine it for leadership lessons for the compliance professional. 

Story Synopsis

All the Pretty Horses was published in 1992. It’s the first book in McCarthy’s Border Trilogy. The story begins in 1949 and is centered around the life of John Grady Cole, a 16-year-old who grew up on his grandfather’s ranch in San Angelo, Texas. After his grandfather’s death, his mother decides to sell the ranch, leaving John Grady, a born and bred cowboy, deeply affected.

Instead of giving in to the changing times, John Grady and his best friend, Lacey Rawlins, decide to head south to Mexico, looking for work as ranch hands. On their way, they encounter a volatile and troubled teenager, Jimmy Blevins, who despite their reservations, joins them. In Mexico, they find work on a vast ranch owned by Don Héctor Rocha y Villareal. John Grady becomes an accomplished horse breaker and falls in love with Don Hector’s daughter, Alejandra, which is forbidden given their different social classes.

However, their peaceful existence is disrupted when Blevins’ past catches up with them. Blevins is accused of horse theft and murder, and John Grady and Rawlins are arrested as his accomplices. Blevins is executed without a trial, while John Grady and Rawlins spend time in a harsh Mexican prison. After enduring the brutal prison conditions, they are released due to the efforts of Alejandra’s great aunt. However, Alejandra, under pressure from her family, ends her relationship with John Grady, which leaves him heartbroken.

John Grady returns to Texas and finds that the world he once knew has changed irreversibly. The novel ends with him setting off into the sunset, uncertain about his future, but with an unbroken spirit and love for the cowboy way of life.

The novel is a coming-of-age story that explores themes of loss, love, and the tension between the old world and the new. McCarthy’s unique narrative style, characterized by minimal punctuation and lyrical prose, underscores the raw beauty and harsh realities of life in the American Southwest and northern Mexico.

Leadership Lessons

All the Pretty Horses presents leadership lessons for the compliance professional through its protagonist John Grady Cole and his experiences. Here are some key leadership lessons we can glean for the compliance professional include:

Decision-Making: John Grady often must make tough decisions, like when he decides to leave his hometown to find a life that suits him better. His choice to help Blevins, despite the risk, also shows a lot about his character. Compliance leadership lesson– compliance professionals must understand that leadership often involves making difficult decisions, with both immediate and long-term consequences.

Responsibility: John Grady takes responsibility for his actions and their consequences. He faces up to his punishments and doesn’t shy away from difficult tasks. Compliance leadership lesson-every compliance professional must accept responsibility for their decisions, good or bad.

Courage: Throughout his journey, John Grady consistently shows courage, whether it’s dealing with the harsh conditions in the Mexican prison or standing up for his values. Compliance leadership lesson– every compliance professional needs to have courage to face adversity, take risks, and stand up for what they believe in. Sometimes you must speak truth to power and be willing to accept the consequences.

Perseverance: John Grady’s determination to survive and maintain his dignity, even in the harshest circumstances, reflects a crucial quality of a leader. Compliance leadership lesson-every compliance professional needs to show determination and the ability to bounce back from setbacks.

Respect and Empathy: John Grady respects the individuals he interacts with, from his fellow cowboys to the horses he works with. Compliance leadership lesson-every compliance professional must respect your colleagues and demonstrate empathy for their challenges in doing business going forward, which are qualities that are critical for a leader to have when dealing with their team.

Integrity: John Grady has a strong sense of moral integrity, sticking to his principles even when faced with challenging situations. Compliance leadership lesson-every compliance professional must always demonstrate integrity in all aspects of your professional life. This is a key trait for leaders, who must maintain integrity and honesty.

Adaptability: Even though John Grady faces a world that is changing around him, he learns to adapt while staying true to his values. Compliance leadership lesson-every compliance professional must adapt to new risks your business meets; whether through new business initiatives or a global pandemic. In short, compliance leaders must demonstrate the ability to adapt to changing circumstances while maintaining core values is crucial.

Failure: Through his relationship with Alejandra, John Grady learns about love, loss, and sacrifice. These experiences, though painful, help him grow and mature as a leader. Compliance leadership lesson-every compliance professional will have failures. How you learn from them will be a key to your development. Compliance professionals need to understand that personal growth often comes through fighting through difficulty.

If you have never done so, I would urge you to read All The Pretty Horses and I hope you find it as moving as I did.

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Sunday Book Review

January 22, 2023 – Top Ethics Books To Read in 2023 Edition

In the Sunday Book Review, I consider books that interest the compliance professional, the business executive, or anyone who might be curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. In today’s edition of the Sunday Book Review, we consider some of the top ethics books which every compliance professional should read in 2023:

·       Ethics for Behavior Analysts by Jon Bailey and Mary Burch

·        Stoic Philosophy and the Control Problem of AI Technology: Caught in the Web by Edward Spence

·       The Rise of Business Ethics by Bernard Mees

·        Business Ethics for Better Behavior by Jason Brennan, William English, John Hasnas, and Peter Jaworski

Resource

20 Best New Ethics Books To Read In 2023 by Annemarie Slaughter

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Sunday Book Review

January 15, 2023 – The Top Business Books to Read in 2023 Edition

In the Sunday Book Review, I consider books that interest the compliance professional, the business executive, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. In today’s edition of the Sunday Book Review, we consider some of the top business books which every compliance professional should read in 2023:

·       How to Win Friends and Influence People by Dale Carnegie

·        Influence, New and Expanded: The Psychology of Persuasion by Robert Cialdini

·       The Compound Effect: Jumpstart Your Income, Your Life, Your Success by Darren Hardy

·        Tools of Titans: The Tactics, Routines, and Habits of Billionaires, Icons, and World-Class Performers by Tim Ferriss

Resource

The Best Business Books to Read in 2023 By Hal Kitzmiller

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Sunday Book Review

January 8, 2023 – The Top AI and Machine Learning Books for 2023 Edition

In the Sunday Book Review, I consider books that interest the compliance professional, the business executive, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. In today’s edition of the Sunday Book Review, we consider some of the top AI and machine learning books that every compliance professional should read in 2023:

·       Future Ready: The Four Pathways to Capturing Digital Value by Stephanie L. Woerner, Peter Weill, and Ina M. Sebastian

·        Digitalization of Financial Services in the Age of Cloud by Jamil Mina, Armin Warda, Rafael Marins, and Russ Miles

·       Power and Prediction: The Disruptive Economics of Artificial Intelligence by Ajay Agrawal, Joshua Gans, and Avi Goldfarb

·        Practicing Trustworthy Machine Learning by Yada Pruksachatkun, Matthew Mcateer, and Subhabrata Majumdar

Resource

The Enterpriser’s Project- 10 must-read tech books for 2023

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Creativity and Compliance

Compliance Confessions – Debunking Employee Myths About Compliance

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network. In this episode, Tom and Ronnie discuss a new video series launched by L&E; why they made them and how they help the compliance professional to debunk myths about the corporate compliance function. In a trailer for a series entitled ‘Compliance Confessions’, we discuss how sharing about how employees feel about compliance and then statements providing a rebuttal to the perception of compliance officer as Dr. No and the corporate compliance function existing as the Land of No,  populated by Dr. No. We also discuss how changing the reputation of E&C from Dr. No can be a valuable communications tool for your compliance function going forward.

Resources:

Ronnie Feldman on LinkedIn

Learnings & Entertainments on LinkedIn

Ronnie Feldman on Twitter

Learnings & Entertainments 

 L&E Offerings

Compliance Confessions 

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Great Women in Compliance

Sue Scott-From Compliance to Coaching

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.

This week we feature another life after Compliance story with Sue Scott.  Sue, originally from South Africa and currently residing in the United Kingdom, is a Compliance veteran with 20 years of experience at HSBC. But this episode doesn’t focus on financial services Compliance, instead we hear Sue’s journey as she considered moving away from Compliance and trying something new.  Mary asks her about her thought process and considerations in making such a big life decision and Sue shares what some of the biggest challenges are for clients at the moment (we’re willing to bet the majority of the Great Women in Compliance audience will find something here relatable – mom/mum guilt anyone?) and Sue shares some coaching advice for how to address some of these issues.

 If you’ve been thinking about getting into coaching, moving into a new area or simply advance planning for your future, this episode will provide helpful considerations and inspiration for taking the big leap – or preparing to do so at least!

For those of you who find that mom/mum guilt is something that resonates deeply, keep an eye out for our upcoming episode with Karina Vollmer where we dive into that challenge in further detail with advice from Karina, a Chief Compliance Officer working mum, or mom as she would say.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings to listen in to.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.  You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020).

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.