Donna Boehme started a discussion about Compliance 2.0. about a year ago. She gets it. Then a speaker at a recent conference talked about Compliance 3.0. I am going on sabbatical soon and will be returning in August to Compliance 6.0. Although it seems that it may be getting a little silly… these people have a point. Our profession is new, people/industries are implementing wildly varying versions of a compliance program. There are people who are implementing half of a compliance program. A lot of people/industries are way behind or way ahead, depending how you look at it. When a new version of software, like an operating system, is enhanced in a material way, the new version is released one number higher like Windows 8.0. I think what is going on in the compliance field is different.
We are not enhancing compliance programs as much as some people aren’t implementing a complete compliance program. Some don’t understand what a compliance program is because the concept is new. Some people are taking some other profession’s methodology (audit, legal risk, ethics) and modifying it slightly and calling it a compliance program. To get people to understand this phenomenon, some are using Compliance 2.0 to describe a complete compliance program.
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Some people are coming to the Society of Corporate Compliance and Ethics’ annual Compliance and Ethics Institute and declaring what we are teaching is advanced compliance. I have been involved in our compliance conferences for 20 years. What we are teaching hasn’t changed. We are teaching the seven elements of a compliance program. There have been improvements, such as more mature speakers and better techniques. But the elements of a compliance program have not changed.
The real benefit of the term Compliance X.0 is that it helps people understand that there is a big gap in the way compliance programs are being implemented. At this fall’s Compliance and Ethics Institute, we will have a general session panel with Marjorie Doyle, Art Weiss, Debbie Troklus and Odell Guyton that I will be moderating. We will be calling it something like Next Generation Compliance. But the truth be told, nothing has changed in 20 years except the number of people who really understand what a compliance program is. This will be the first time we have directly addressed the problems we are having with people and entire industries implementing some variation of an incomplete compliance program.