This article was republished with permission from Michael Volkov’s blog, Corruption, Crime & Compliance.
With the rise of the compliance professional, there is a real need for strong support as they design and implement new and innovative compliance programs.
Compliance professionals are stretched thin – they have a mountain of responsibilities but only an anthill of resources to commit to the job. They are constantly putting out fires, prioritizing tasks and allocating scarce resources or urging other parts of the company to promote or assist the compliance function.
Professional associations, lawyers, consultants, vendors/suppliers and other support persons have a duty to the compliance professional. They need to take a different approach – one that is more focused on real-life solutions to real-life problems.
I have to start with another one of my life lessons – the ability to empathize and see issues from another person’s perspective. Compliance practitioners do not need theoretical solutions or long-winded explanations of why this approach works or another does not work.
Instead, compliance professionals need support with practical solutions to real problems. In some cases, compliance support professionals can help to define a strategy to solve a problem. Sometimes the same strategy or a similar one worked for another compliance professional in another company.
Compliance professionals also do not need lengthy recitations on the history of a particular law, unless that history is immediately relevant to the current situation. All too often, lawyers who support compliance professionals fill their emails and telephone calls with long-winded legal explanations that have little to no relevance to the compliance professional who is trying to solve a problem.
In many cases, compliance professionals need a bottom line on what needs to be done and an adequate discussion of why the action needs to be taken. A Big Lebowski solution focusing on the “ins and outs” of an issue can be inefficient and a waste of time for a compliance professional.
Benchmarking among compliance professionals is an important source of information and assistance for problem solving. No two companies are exactly alike, but there are lessons to be learned from benchmarking similarly sized companies or regulated companies.
Compliance professionals are very collegial and willing to help each other out. They often share information, drafts and policies/procedures among themselves. They also consult with each other on occasion.
CCOs work by themselves or with small groups. They often have a small staff. They have fewer opportunities to develop solutions through staff discussions. Often, they arrive at solutions by working closely with legal staff and their clients – the business managers.
In the end, compliance professionals need less theoretical mumbo jumbo and more practical, real-world solutions. As a theoretical matter, it may be great to conduct due diligence of all suppliers/vendors who have annual revenues exceeding $50,000, but a compliance professional may not have the resources to conduct such a review and may be left with a strategy that focuses on the top 10 or top 20 vendors/suppliers based on geographic areas of operation.
The compliance industry should start to focus more on these kinds of issues. It is time to give compliance professionals the support they need and the support they deserve.
