Categories
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.

Categories
Innovation in Compliance

Creating the Insights Lab with Zachary Coseglia

In this insightful episode of the Innovation In Compliance podcast, Tom Fox welcomes Zachary Coseglia, the founder of the Ropes & Gray Insights Lab, to talk about the creation of the unique consultancy within the law firm. Zach dives into the challenges of building a team with diverse skill sets and backgrounds for a new function like the Insights Lab. He shares the value of data analytics for compliance, and how it can be used to improve investigations and understand patterns of behavior across the organization. Zach also highlights the complexities of working in-house, including managing relationships and understanding organizational intricacies. 

With over a decade of experience in the pharmaceutical industry, healthcare, and life sciences, Zach Coseglia built a strong background in investigations, compliance analytics, and digital compliance. During his time as head of investigations in Asia Pacific for Pfizer, he came up with the idea to create an analytics and behavioral science consultancy within a law firm, which led to the birth of the Insights Lab.

 

Key takeaways from the episode include:

  • Building an analytics consultancy within a law firm or compliance department requires investment in technology and human capital. Zach brought together people with diverse skill sets, backgrounds, and experiences to build a team that reflects the needs of the consultancy being created. He combined subject matter expertise of compliance and data analytics to build the team for the Insights Lab.
  • Zach believes that to build a successful analytics consultancy within compliance, it’s important to bring in people who have done this work in other industries. He stresses that they can bring unique perspectives and experiences that can drive innovation and progress within the organization.
  • The potential of data analytics to promote a better, stronger compliance program through identifying trends, patterns of behavior, and driving efficiencies.
  • Zach reflects on his experience working in-house and highlights the challenges of managing relationships and understanding organizational intricacies. He stresses the importance of effective relationship building and an intentional and strategic approach to building new capabilities or functions within an organization.
  • Compliance is a deeply human discipline that involves shaping human behavior through policies, procedures, training, and programs. Behavioral science, cultural psychology, and behavioral economics play a critical role in compliance and ethics work.
  • Compliance programs that only focus on rules are short-sighted.
  • Human-centered design is a powerful approach to building effective compliance programs that engage with people and amplify their voices.
  • The Insight Lab at Ropes and Gray is a consultancy, analytics, behavioral science, and creative consultancy that aims to combine multidisciplinary expertise under one roof.  The lab includes a team of lawyers, data journalists, ethics experts, journalists, and specialists in cultural psychology and behavioral science. The lab has expanded beyond compliance consulting to focus on areas such as organizational culture, diversity, equity, and inclusion, and environmental social governance (ESG).
  • The team’s multidisciplinary approach can shape the future of legal work, and the lab has the potential to be a large, powerful business for Ropes and Gray.
  • Law firms are embracing multidisciplinary teams and creating their own consulting groups, with some firms recognizing the value of analytics and behavioral science consultancies.
  • The legal profession could benefit from acknowledging that other disciplines can help make it stronger.
  • Zach Coseglia and Hui Chen have started a podcast called “There Has to Be a Better Way?” which is an innovation and curiosity podcast focused on identifying better ways and people who are finding their own better ways to solve organizational challenges, such as compliance, ethics, risk, diversity, equity, inclusion, and organizational culture.

 

KEY QUOTES:

“I think that there’s a huge opportunity for us to embrace behavioral science, to embrace a more scientific point of view, to embrace the world of data in ways that actually advance our profession.” – Zach Coseglia

 

“With all of the data we had available to us, we have this opportunity to understand human behavior in ways that go beyond just the rules.” – Zach Coseglia

 

“I have felt for a long time that compliance is being treated – has been treated – as this exclusively legal, regulatory, enforcement-related exercise oftentimes led by lawyers, when in fact, compliance is a deeply human discipline.” – Zach Coseglia

 

Resources:

Zach Coseglia at R&G Insights Lab | LinkedIn 

Ropes & Gray Insights Lab | Podcast: There Has to Be a Better Way?

Categories
Daily Compliance News

June 9, 2022 the FBI Sued Edition


In today’s edition of Daily Compliance News:

  • DOJ hires HP CCO to run Fraud Section. (WSJ)
  • Hui Chen moves to R&G Insights Lab. (WSJ)
  • Gymnasts sue FBI for $1bn. (WSJ)
  • New SEC rules on equity trades. (WSJ)
Categories
The Compliance Handbook

Evolution of Compliance Programs with Hui Chen


In this special episode, Compliance Evangelist Thomas Fox sits in an engaging and value-packed discussion with Hui Chen, former compliance consultant to the U.S. Department of Justice’s Fraud Section and now chief integrity officer for the Hawaii Attorney General’s office.
KEY TAKEAWAYS:
✔️  Hui advocates the need for a very interdisciplinary approach to compliance. Practitioners should become open to learning about social sciences and quantitative and qualitative studies, scientific methods, understanding how research is done, evaluating research outcomes, and evaluating the application of research.
✔️   Realize that people don’t govern their daily lives by reading the codes and the regulationsbut with processes and behaviors, and that’s what should be focused on by using a behavioral-based approach. Give the organization reason, opportunities, or motivations to NOT engage in the behavior you don’t want them to do.
✔️  What differentiates compliance officers is their knowledge and familiarity with the business. It is required to be versatile in understanding every function in the organization and working with them. Compliance professionals need to develop those skill sets to appreciate and understand and measure and be part of what the business does in all of those aspects.
✔️ How do we measure that outcome? By going back to define what you are doing this for, if you do it successfully, what success looks like, and try to find measurements for that, that is important because that goes to whether we have all been wasting our time not with the compliance programs.
Hui is an internationally renowned leader in ethics and compliance. She regularly consults with companies as well as regulatory and enforcement authorities around the world, advising them on the design, implementation, and assessment of ethics & compliance programs. Hui is also a thought leader who collaborates with leading academic researchers and publishes regularly in business and academic journals. 
Chen did this interview entirely in her personal capacity and nothing she said should be attributed to her office.
Connect with Hui Chen
Website: www.HuiChenEthics.com
Twitter @HuiChenEthics
____________________________________________________________________
The “Nuts and Bolts” for Creating a Comprehensive Compliance Plan 
This chapter of this unique work lays out a succinct yet thorough one month approach to operationalizing a company’s compliance regimen. Beginning with a section on what 2020 brought to the compliance landscape, each chapter methodically outlines best practices for everything from establishing policies, procedures, and internal controls, to assessing risk, training, handling investigations, and more. Each day ends with three key takeaways you can implement at little or no cost.
Understanding Compliance Responsibility Across the Organization
The Compliance Handbook also takes a close look at all professionals’ roles with compliance responsibility, from Compliance Officers and Boards of Directors to Human Resources, to Internal Audit and Internal Controls and Communications and Training professionals.
In-Depth Treatment of Hot Topics and Trends
The Handbook provides an in-depth look at the latest thinking and trends for the full range of critical compliance topics, including:

  • Compliance and business ventures
  • Third-party risk management
  • The Board’s Role in Compliance
  • Continuous improvement
  • Compliance innovation
  • And much more.

Incorporating Current Government Pronouncements
The Second Edition incorporates the most current government pronouncements governing best practices compliance programs, including the 2019 Evaluation of Corporate Compliance Programs released by the Fraud Section of the Department of Justice, and its 2020 Update; the updated FCPA Resource Guide 2nd edition; the Framework for OFAC Compliance Commitments; and the 2019 DOJ Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust.
eBooks, CDs, downloadable content, and software purchases are non-cancellable, non-refundable, and non-returnable. Click here for more information about LexisNexis eBooks. The eBook versions of this title may feature links to Lexis + for further legal research options. A valid subscription to Lexis + is required to access this content.
Order your copy OR copies of The Compliance Handbook: A Guide to Operationalizing Your Compliance Program. Save 25% off.
http://www.lexisnexis.com/fox25