Why Do Compliance Programs Work?

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Why do compliance programs work?

2014-snell-roy-speaking-headshot-200By Roy Snell
roy.snell@corporatecompliance.org

The most wildly successful concepts introduced into society often have this in common: they are elegant, simple, and effective. Compliance programs work because they are simple, elegant, and effective. Many people want to make compliance programs complicated, but when they do, they ruin their effectiveness.

Compliance programs work because they are the obvious solution. To understand why they are so effective, you have to understand their purpose: “To prevent, find, and fix ethical and regulatory problems.” To prevent a problem, you have to educate, put in controls, have effective reporting of issues, etc. To find a problem, you have to audit, investigate, etc. To fix a problem, you have to correct, discipline, and report.

All these tools have been around for years, but they have been siloed into separate departments. So when it came to correction and discipline, there have been many epic failures. Everyone was in charge, so no one was in charge. Compliance professionals, however, implement all these tools in a comprehensive, coordinated manner (with the help of interpersonal skills, such as influence) to ensure successes… instead of crawling under a table when a problem is found.

There are people who want to change Chapter 8 of the U.S. Federal Sentencing Guidelines, despite that it has been successful guidance for over 20 years and still applies to every type of company. And some people want to create a standard and a certification for compliance programs. But the reason that Chapter 8 still works is because it is simple and elegant. Adding more detail will ruin it. And where do you stop? (One organization I know of has a description of a compliance program that is hundreds of pages long!) If everything is important, nothing is important.

All this effort to complicate a simple and elegant solution will kill compliance program effectiveness.

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3 COMMENTS

  1. Reminds me of a quote..No not the often used “KISS” but rather one we used A LOT in process design. “Simplicity is the ultimate sophistication”…Leonardo da Vinci.

  2. Nice post. “When everything is important, nothing is important.” I like it. Chapter 8 is complete. We don’t need a “new” standard foisted on us by non-subject matter experts for profit. We must mount an organized challenge to any attempt to do so.And yes, an effective program is simple, but here’s what’s not so simple=> understanding how the various program elements work and interface in a manner that can support a culture of accountability. That’s where Compliance 2.0 and subject matter expertise/experience come in. No more “Indiana Jones Compliance”!

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