I was asked what to do if the compliance department was performing as the in house counsel rather than a compliance department. This was my answer…
Leaders need to work with the in-house counsel and the compliance team to clarify and delineate their roles. Once that is accomplished, if the compliance officer is still running a legal department and not a compliance department, they need to be replaced. This is really not a matter of tactics or strategy. It’s not complicated. The answer is to just get it done. Whomever the two departments report to, is responsible and quite often the only people that can fix it.
If leadership is open to learning and just doesn’t really understand the difference between the two departments, they should consider attending a compliance conference. They will learn from many people through many different presentations… that there is a material difference between the two departments. I would also consider hiring an outside consultant to help… but leadership has to understand and believe in the direction they need to go which might only come through education. The function of the compliance program and the role of the compliance and ethics department is a new concept. If ever there was a case for an experienced leader to go back and get some education to keep up with the changing times… this is it. A lot is at stake… just ask John Stumpf.
[clickToTweet tweet=”What if the Compliance Department is Run Like A Legal Department?” quote=”What if the Compliance Department is Run Like A Legal Department?” theme=”style3″]