By Roy Snell
As a compliance officer, you have to be passionate about preventing, finding, and fixing problems. If you are, you will prevent, find, and fix problems. People tend to be successful at what they are passionate about. All too often we have compliance officers who are passionate, but they are passionate about one thing. Some are passionate about building an ethical culture. They may have the best ethical culture, but they will not find and fix problems created by unethical people. You can’t have a successful compliance program if you don’t look for problems. Some are passionate about the rule of law. They may have all the answers about what is within the rule of law, but passion about the rule of law will not educate people as to what the rule of law is. A compliance program will not be successful without education. Some are passionate about risk assessments, but predicting where the big problems might be, doesn’t find the problems that might be there. Compliance programs will not be successful if you don’t audit to see if the problem is where you suspect it is.
Being passionate about one element of a compliance program will help ensure that one element is successful. However, the whole reason our profession was created was because people were passionate about the rule of law, or risk, or auditing, or building an ethical culture. They failed because they all operated independently, and no single person was passionate about preventing, finding, and fixing ethical and regulatory problems.
Thought leaders will tell you, “The key to compliance is…” The answer is almost all ways different and, coincidently, happens to be what that thought leader is passionate about. It’s a trick question, because there is no key to compliance programs—there are many keys. You have to audit, educate, analyze the rule of law, do risk assessments, develop policies, have an effective reporting system, build an ethical culture, convince people to address known issues, etc. You have to care about the big picture. You have to be passionate about the outcome of the compliance program rather than one element of the process.
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