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Corporate Compliance Insights

What Does Good Compliance Look Like?

by Richard Bistrong
January 25, 2016
in Uncategorized
What Does Good Compliance Look Like?

This article originally appeared on Richard Bistrong’s FCPA Blog and is republished here with permission.

At a corporate summit, the CEO of a Fortune 500 company started his talk by asking, “what does good look like?” Good question.

“Rules often inspire legalism and minimalism,” he said. “But  they don’t govern behavior.”  He shared that compliance personnel face the challenge of impacting and inspiring people outside their formal perimeter yet who are part of their team. In organizational chart terms, that’s about influencing the dotted lines of reporting, not just the solid lines.

During 2015, my first full year engaged with the compliance community, I realized that the compliance focus is about helping and supporting those in the field, often in remote and thinly supervised offices. It’s about finding and strengthening the weak links.

I used to think, through the prism of my experience, that compliance was focused on “catching people doing bad things.” But the “catching people” moment, I now realize, is when all else fails. As the former poster boy for a tight control regime, I now understand and respect those distinct compliance goals, even if they are intertwined in the same program.

So I started asking myself, how can I help and support? I started with prison, which was an awful experience. The family and health consequences were disastrous. So I started to share my experience as a “tipping point” for those who confront similar ethical dilemmas that I faced, and which ended with my incarceration. I hope that a real-world crucible invites others to avoid that outcome by embracing compliance as a partner to success.

As my 2015 progressed, I started encouraging people to speak up when they feel that success and compliance are competing ideas and goals, as opposed to strategic counterparts.  I encouraged them to “call home” first, but also to call compliance.  I also challenged compliance personnel to look from within to see if there were any “unspoken” organizational messages or silos that might be causing confusion in the field.

I spent the better part of my career avoiding and evading compliance. But I now appreciate that compliance leaders want those outside of their perimeter to be successful, and they want them home with their families.

I no longer call compliance personnel the “bonus prevention” people.  I call them friends and colleagues. In my next blog, I’ll get back to “what does good look like” and invite your thoughts.


Tags: Tone at the Top
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Richard Bistrong

Richard Bistrong

Richard Bistrong, CEO of Front-Line Anti-Bribery LLC Former FCPA Violator and FBI/UK Cooperator; Anti-Bribery Consultant; Writer & Speaker Richard Bistrong spent much of his career as an international sales executive in the defense sector and currently consults, writes and speaks on foreign bribery and compliance issues from that front-line perspective. Richard’s experience included his role as the Vice President of International Sales for a large, publicly traded manufacturer of police and military equipment, which required his residing and working in the UK. For well over 10 years, Richard traveled overseas in his sales responsibility for approximately 250 days per year. In 2007, Richard was targeted by the U.S. Department of Justice in part due to an investigation of a UN supply contract and was terminated by his employer. In that same year, as part of a cooperation agreement with the DOJ and subsequent Immunity from Prosecution in the United Kingdom, Richard assisted the United States, Great Britain and other governments in their understanding of how FCPA, bribery and other export violations occurred and operated in international sales. Richard’s cooperation, which spanned three years of covert cooperation and two years of trial preparation and testimony, was one of the longest in a white-collar criminal investigation. In 2012, Richard was sentenced as part of his own plea agreement, and served fourteen-and-a-half months at a federal prison camp. Richard was released in December of 2013. Richard now consults, writes and speaks about current front-line anti-bribery compliance and ethics issues. Richard shares his experience on anti-corruption and ethical challenges from the field of international business, reflecting on his own perspective and practice as a former sales executive and law enforcement cooperator. Richard currently consults with organizations through his company, Front-Line Anti-Bribery LLC, and welcomes the opportunity to exchange and share perspectives on real-world anti-bribery and compliance challenges.  Richard has shared his experience, via keynotes and panels, with the OECD, World Bank and International Anti-Corruption Academy, as well as major multinationals and leading academic institutions. Richard can be reached via his website www.richardbistrong.com  or email richardtbistrong@gmail.com and he frequently tweets on #FCPA & #compliance via @richardbistrong.  Abstracts on his consulting practice can be found on his website. Richard is also a Contributing Editor to the FCPA Blog at www.fcpablog.com.

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