Tag: compliance professional

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Responsible Steward for Managing Risk

How does compliance demonstrate its value when enforcement priorities change? That question keeps coming up in conversations with compliance professionals. It deserves an answer grounded in the work companies do every day: making sound decisions, protecting resources, maintaining trust, and pursuing opportunities within appropriate boundaries.

In a recent conversation with Anik Shah, we explored how compliance can remain relevant during enforcement uncertainty. Anik offered a phrase that captured the responsibility exceptionally well: “responsible steward for managing risk.”

I immediately told him that phrase deserved a blog post. It provides a useful organizing principle for the next evolution of compliance. Stewardship combines professional judgment, business understanding, and accountability. It also creates an obligation to leave the organization better equipped to manage risk than before. For CCOs, that means explaining risks accurately, recommending workable responses, and ensuring that decision-makers understand the consequences of their choices.

Credibility Begins with an Accurate Assessment

Shah emphasized that credibility is the compliance professional’s most important currency. Its value depends on whether management can rely on our advice. When enforcement priorities change, compliance must acknowledge the change. Repeating yesterday’s assessment without examining today’s circumstances weakens our standing with business leaders who can see that the environment has shifted.

In February 2025, the Trump Administration issued an executive order directing a pause in initiating new FCPA investigations and enforcement actions, alongside a review of existing matters. DOJ subsequently issued revised enforcement guidelines on June 9, 2025, emphasizing American economic and national security interests. Those developments changed enforcement policy; they did not repeal the FCPA.

A credible CCO explains that distinction and then examines the company’s actual exposure. Which government interactions, intermediaries, transactions, and jurisdictions warrant attention? What has changed in the likelihood of scrutiny? Which legal obligations and business vulnerabilities remain?

International developments also matter. In March 2025, authorities in the United Kingdom, France, and Switzerland established an anti-corruption prosecutorial task force to strengthen collaboration. The European Union’s new anti-corruption directive entered into force in May 2026, with national implementation generally required within two years and additional time for certain provisions. These developments require multinational companies to assess obligations across their operating footprint.

Precision also means avoiding sweeping claims about limitation periods. Counsel should assess the applicable offense, jurisdiction, and any tolling issues. A proposal to extend a limitation period must be described as a proposal. Credibility suffers when an urgent message depends on an overstated legal premise. The responsible steward makes the strongest accurate case available.

Stewardship Turns Analysis into Decisions

Shah described stewardship as leadership: helping the company navigate risk through clear, actionable advice. That requires compliance to understand what the business is trying to accomplish. Consider a hypothetical proposal to enter a new market through a distributor. The distributor has strong government relationships, requests substantial commissions, and provides incomplete ownership information.

A useful compliance assessment connects those facts to a decision. It identifies the information required before approval, explains the concerns surrounding compensation and ownership, and proposes conditions for proceeding. Those conditions might include verified beneficial ownership, documented services, payment controls, contractual protections, and continuing monitoring.

Management should also understand the alternatives. It could use another distributor, narrow the proposed engagement, delay entry while questions are resolved, or abandon the arrangement if material concerns cannot be addressed. This approach gives decision-makers a clear view of the opportunity and its constraints. It also makes accountability visible. Management owns the business decision within established authority; compliance provides independent advice, challenges unsupported assumptions, and escalates unacceptable conduct.

Stewardship includes the willingness to stop a transaction when necessary. Commercial pressure cannot convert prohibited conduct into an acceptable risk. The discipline is to explain the reason, document the decision, and identify a lawful path forward where one exists.

Demonstrate the Business Value of Controls

Shah also identified compliance benefits that deserve greater attention in management discussions: detecting waste, fraud, and abuse. An expense review may uncover duplicate reimbursement, unsupported entertainment, or spending inconsistent with company policy. Third-party diligence may reveal an undisclosed employee relationship. A review of payments may identify services that were never delivered.

Each finding can protect company resources and improve management information, even where no bribery violation is established. CCOs should make those outcomes visible through evidence. Report substantiated recoveries, recurring control failures, corrective actions, and improvements in review time. Explain how the findings changed a process or prevented a known weakness from continuing.

Be disciplined about financial claims. Hours released for other work do not automatically become cash savings. Distinguish estimated losses avoided from money actually recovered. That discipline reinforces the larger argument: compliance contributes to business performance through better decisions and stronger controls. Its value can be demonstrated without assigning a speculative dollar amount to every activity.

Boards should expect that connection. A report showing policy completion rates becomes more useful when it also explains whether employees apply the policy and whether identified weaknesses are being corrected.

Trust Must Be Earned in Daily Operations

Our conversation returned repeatedly to trust. Employees need confidence that raising a concern will lead to a fair response. Business leaders need confidence that compliance advice reflects sound judgment. Directors need confidence that significant issues reach them promptly. Those expectations are connected.

A company that invites employees to speak up must have managers prepared to listen. Reports should receive appropriate attention, investigations should be conducted fairly, and employees should receive meaningful updates within confidentiality constraints. Promotion and compensation decisions reinforce the message. If a manager repeatedly overrides controls yet continues to advance because of strong sales, employees will draw their own conclusions about the company’s priorities.

CCOs should examine those signals with human resources and business leadership. Ask whether ethical conduct affects performance assessments, whether repeat exceptions receive scrutiny, and whether corrective action applies consistently across organizational levels. Stewardship also requires institutional continuity. Document important judgments, develop colleagues, and preserve the reasoning behind significant decisions. A program dependent on one individual’s memory or relationships remains vulnerable when that person leaves.

Use AI to Create More Room for Judgment

AI was an important part of our discussion because it can support stewardship work. The practical opportunity is to reduce time spent gathering and sorting information so compliance professionals can focus more on interpretation, investigation, and advice. Expense review provides a useful starting point. A controlled pilot could assess whether a tool helps identify duplicate submissions, missing documentation, unusual spending patterns, or transactions requiring additional review.

Begin with a defined population and a documented baseline. Compare the tool’s output with experienced reviewers. Examine false positives and missed issues, including a sample of transactions the tool did not flag. Measure total review time, including the effort required to resolve alerts. A flagged transaction should prompt examination. An employee deserves a fair assessment of the facts before any conclusion is reached.

Regulatory monitoring offers another practical use case. An AI-assisted process could collect developments from approved sources, summarize changes, and route potentially relevant items to responsible specialists. Its usefulness depends on verification. The process should preserve the underlying source, distinguish proposals from enacted requirements, identify effective dates, and connect developments to the company’s activities. A confident summary that omits a jurisdictional limitation can send the business in the wrong direction.

For both applications, establish ownership, access controls, confidentiality protections, and procedures for addressing errors. Determine whether the tool is approved to handle the information involved. Review performance when the model, data, or business process changes. The management case should be specific: faster identification of relevant issues, broader review coverage, or additional capacity for substantive advice. Present measured results alongside implementation costs and unresolved limitations.

Success in expense review does not establish suitability for preparing financial statements. Each materially different use requires its own assessment, testing, and accountable oversight. Most importantly, decide how released capacity will be used. Time saved can support deeper third-party reviews, stronger investigations, or earlier involvement in business planning. Technology delivers compliance value when it improves decision quality and timeliness. Professional judgment remains necessary to determine what an anomaly means, what action is proportionate, and when an issue requires escalation.

Put Stewardship into Practice

CCOs can translate this approach into five immediate actions:

  1. Refresh the risk narrative. Explain what has changed, what remains applicable, and how the assessment affects priorities.
  2. Provide decision-ready advice. Present options, conditions, owners, and escalation points alongside identified risks.
  3. Demonstrate operational value. Track substantiated outcomes and distinguish measured benefits from estimates.
  4. Test trust. Examine reporting experiences, management responses, incentives, and consistency of accountability.
  5. Pilot AI with clear controls. Define the use case, validate performance, and direct released capacity toward higher-value judgment.

Boards should ask whether compliance has sufficient authority and information to challenge decisions, whether management acts on significant findings, and what evidence demonstrates improvement.

Being a responsible steward for managing risk means accepting responsibility for the quality of the guidance we provide and the capabilities we help build. That is a durable basis for compliance leadership through changing enforcement priorities, new technologies, and the next business opportunity.

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The Missing Link in Compliance: Building an Effective Advice Function

In a best-practices compliance program, a policy explains the rules. Training can introduce the risks. But when an employee faces an unfamiliar request, they still need to know what to do now, before making a commitment that changes everything. The question may arrive while a customer waits, a payment is pending, or a team prepares to launch a product. At that moment, “please consult the policy” may identify a resource without resolving the decision. Compliance should equip people before they improvise, not merely evaluate their improvisation afterward.

Your corporate compliance function should routinely advise employees on all compliance-related issues. But when did you last evaluate this ‘advice function’ as part of the compliance program? Training should help employees recognize when a question exists. Guidance should help resolve it in the actual circumstances.

A mature design therefore asks where important decisions occur, who needs help, and how quickly your compliance function can respond. A small company may use a straightforward contact arrangement with clear backups. A larger organization may need specialist routing across functions and time zones to ensure complete coverage. Neither should depend entirely on employees knowing the right person personally.

Make the route visible in the workflow where the question arises. An approval screen, travel process, vendor request, or data-sharing step can direct the user to the right assistance without requiring a search of the entire intranet.

The Corporate Translation: A Question Before the Commitment

Consider a hypothetical business development team preparing an important demonstration. An external platform could make the presentation more compelling. A team member suggests uploading records from an existing customer so the demonstration reflects real business conditions. The deadline is tomorrow. The platform has not been reviewed for that use.

One employee remembers the company’s data-handling training but is unsure whether a limited demonstration falls within the existing rules. The employee needs an answer before the upload, not a general reminder the following week. A useful response identifies the immediate boundary, the facts requiring review, and a workable alternative. For example, the adviser may explain that company policy requires pausing the proposed upload while the team uses approved synthetic demonstration data.

The commercial objective continues through an authorized route. The unresolved platform assessment remains a separate task with an owner. That is preventive compliance: reducing uncertainty while there is still an opportunity to choose a better course.

Distinguish Advice, Approval, and Reporting

Employees should not have to understand the company’s organizational structure before asking for help. But the company must distinguish what happens after the question arrives. Compliance advice and counseling explain expectations and possible courses of action. Approval authorizes a defined activity within delegated authority. Reporting communicates a concern that may require assessment or investigation. One conversation can involve all three. It should not silently substitute one for another.

In the demonstration example, explaining the synthetic-data option does not approve the external platform for unrestricted use. A security assessment may inform the decision without completing a contractual review. A disclosure that records have already been uploaded requires a different response than a prospective question. State the status clearly. Identify what is authorized, what is prohibited under the applicable requirements, what remains unresolved, and who owns the next decision. Do not describe every advice request as a suspected violation. At the same time, do not leave credible allegations in an informal advice queue because the original employee selected the wrong category.

Ask for the Facts That Change the Answer

A useful intake process gathers enough information to understand the decision without unnecessarily complicating the request. Ask what the employee proposes to do, which parties are involved, what has already happened, and when the next irreversible step occurs. Identify the relevant information, payment, benefit, representation, or commitment.

Then ask what could change the answer. In our hypothetical, that may include the type of records, existing permissions, platform terms, intended audience, and whether the information would remain stored afterward. Let the employee say a fact is unknown. An intake form should not force a confident answer where none exists.

A compliance professional should avoid collecting unrelated personal information or demanding a full investigation before providing preliminary guidance. Begin with a safe interim direction where appropriate, then assign the additional review. But a compliance professional should also test the claimed deadline. Some deadlines reflect genuine operational needs. Others reflect a late request or an assumption that nobody can change the schedule.

Make the Response Usable

Your employee needs a response they can act on, not one they can only admire for its precision. Explain the concern in business terms. Identify the action that may proceed and the action that must wait—state any conditions, the responsible decision-maker, and what new facts would require reconsideration. In our hypothetical, a practical response might confirm an approved demonstration method, identify the owner of the external-platform review, and explain that permission for the demonstration does not authorize later customer-data uploads.

Preserve the reasoning proportionately. A brief written answer may be enough for a straightforward question. A consequential decision may require a fuller record and formal approval. Do not use conditional language that nobody owns. “Proceed once all requirements are satisfied” is incomplete unless someone knows which requirements apply and who verifies completion. Yes, you knew I would slip in Document Document Document at some point.

Give Advisers Authority and Reliable Backup

A corporate compliance function needs authority, access, and resources to influence decisions before risk is accepted. Timely advice is one way to operationalize that independence. A compliance professional should know when it can answer directly and when another function must decide. Give advisers escalation routes for unresolved legal, technical, operational, and commercial questions.

Provide backup for absence and specialist coverage. A program that relies on one expert to answer every urgent message recreates key-person risk. Define what happens when business and compliance disagree. Preserve the competing assessments and route them to the authorized decision-maker. Do not allow repeated requests to different advisers to produce an undocumented approval search.

Maintain an appropriate record of previous advice so that the next adviser can see the relevant history. Restrict sensitive information and involve counsel when legal privilege or other protections may apply; do not promise protections the process cannot guarantee. Employees should be able to trust the service without being told that every conversation is secret or every answer is final.

Measure Helpfulness, Not Just Response Speed

A fast acknowledgment is useful. It is not the same as a resolved question. Measure time to an actionable response, time to final resolution, and reasons for delay. Separate time spent waiting for missing information from time lost because the request had no owner.

Review whether employees understood the answer and followed the approved path. Sample a small number of completed requests and compare the guidance with the subsequent transaction or activity. Also look for unnecessary complexity. If routine questions repeatedly require several functions to restate the same policy, clarify the process rather than celebrating the volume of collaboration.

The 2024 Evaluation of Corporate Compliance Programs asks whether employees know when to seek compliance advice, how to do so, and whether they are willing to do so. Availability alone does not answer either question. Use feedback carefully. Satisfaction is relevant, but a correct refusal may disappoint the requester. Conversely, a popular answer may be insufficiently supported. Assess the reasoning, the clarity of the next step, and the result. Speed belongs in that assessment but should not dominate it.

Managers Determine Whether Asking Feels Practical

Imagine an employee using the advice service correctly, only to hear from their manager that the question should never have been raised. The channel exists. The local message defeats it. A culture of speaking up exists only if it’s matched by a culture of listening up.

Managers should model asking early, providing necessary facts, and responding constructively when the answer changes the plan. Include those behaviors in manager training and leadership expectations, and evaluate them through real examples. Give teams protected time for review. A manager cannot repeatedly create last-minute commitments and then treat the resulting control discussion as evidence that compliance is slow.

Equally, compliance should examine its own delays. An inaccessible or inconsistent service should not place the burden of its design failures on the employee. Train managers to receive uncertainty without demanding an immediate conclusion. “Let us establish the facts before we commit” is a useful leadership response. Where concerns involve the manager, provide another route. Advice should not require the permission of the person whose instruction is being questioned.

Turn Repeated Questions into Better Design

An advice log can reveal where policies, training, and workflows leave employees uncertain. Repeated questions about one approval may indicate vague or imprecise instructions or even an unclear policy. Questions arriving after commitments may indicate that the control sits too late in the process. Different answers to the same facts may indicate that advisers need alignment. Treat those patterns as hypotheses to investigate, not conclusions to impose.

NIST SP 800-50 Revision 1 approaches cybersecurity and privacy learning through audience needs, behavior change, evaluation, and improvement. Applying that learning-cycle logic to compliance guidance can help connect recurring questions with targeted program changes. For the demonstration team, a useful improvement might be an approved dataset library and a clear route for reviewing external tools. That would address the underlying business need rather than simply repeat the prohibition. Test the revision with the people performing the work. Can they find the approved materials? Do the materials meet the legitimate purpose? Do they know when a different use needs review?

The Compliance Takeaway

The bottom line for a compliance professional is to recognize the situation, explain the issue, provide usable help, and do so before the critical encounter. For companies, that means making advice available where decisions happen. It means clear ownership, appropriate expertise, reliable escalation, and answers that distinguish permission from unresolved questions.

The business should not need a heroic employee to find the one person who understands the issue. Nor should compliance require a crisis before it becomes accessible.

Return to the demonstration. The employee asked before uploading the records. The adviser identified a responsible alternative. The team continued its work without treating the deadline as permission to ignore the concern. That is the result to design for.

The best time to explain the antidote is before someone needs to recover from the exposure.

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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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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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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.

Categories
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

Categories
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

Categories
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