From time to time I ask Chief Compliance Officers (CCOs), “What is a common, but frustrating, part of your daily routines on the job? What problem arises all the time that you can’t ever seem to solve?” Two recent responses are worth considering in a bit more depth because they highlight what a day in the life of a CCO is really like.
First one was a CCO’s gripe about due diligence. “The sales executive doesn’t complete the due diligence form we provide,” this person told me. “I kick it back to him so the form can be completed, but by then he’s moved on to his next prospect. So the due diligence process stalls — and he starts complaining to me that due diligence takes too long. Then my forehead looks for the nearest available wall.”
We can all feel that CCO’s pain, even before he begins banging his head against the wall. In this case, the business executive still sees compliance as something other, something apart from his “real job.”
Another answer came from a compliance officer who handles investigations. “The most common refrain I get from people — even ones I’m not investigating, just asking for information — is suspicion,” she said. “So they ignore me, or provide too little information, and I keep coming back to them. Then they start asking, ‘Why does this take so long?’ ”
Both frustrations really trace back to the same root problem: a workforce reluctant to engage with the compliance function.
That reluctance leaves compliance unable to do its job efficiently. And once you’re forced to do the job inefficiently — circling back to business unit employees, asking for more cooperation over and over — well, a day in the life of a CCO can get pretty frustrating.
That’s true whether you’re a mid-level compliance professional working on specific cases, or a chief compliance officer forging deeper ties with the rest of the enterprise and asking for more resources. A workforce reluctant to engage with compliance leaves you struggling in a host of ways, great and small.
A New Day in the Life of a CCO
Breaking that paradigm isn’t easy. It requires a compliance officer to work across multiple fronts, employing different skills in different ways, to convince others that working with the compliance function is a good thing.
Above all, interpersonal skills and business acumen matter. Without them — without that ability to understand the problems of other constituencies in the business, and how compliance might address those problems — you’ll never be able to do more than force your way into their lives “because this is what the law requires us to do.”
We’ve discussed the need for these skills before, including how internal audit executives face the same challenge: How does a risk assurance function, like audit or compliance, also offer something useful to operations functions? You need finesse with people, and an ability to perceive their problems.
That said, you also need skills in managing technology. Better use of technology is how compliance can help those exasperated business units, usually by automating some of those reporting duties off of their plates. Think about it: large organizations already face organizational restructuring, regulatory change, or shifting perceptions of what ethical behavior actually is.
Pivoting to those changing expectations is hard, and technology is how a company pivots. So an ability to work with complex IT systems, smoothing a path to achieve all those shifting objectives, is crucial.
Bring those two skill sets together, and suddenly compliance can work much more productively with other parts of the enterprise to fulfill your objectives and theirs together. Then a day in the life of a CCO won’t feel like the daily grind it can seem today.
Matt Kelly is an independent compliance consultant and the founder of Radical Compliance, which offers consulting and commentary on corporate compliance, audit, governance, and risk management. Radical Compliance also hosts Matt’s personal blog, where he discusses compliance and governance issues, and the Compliance Jobs Report, covering industry moves and news. Kelly was formerly the editor of Compliance Week. from 2006 to 2015. He was recognized as a "Rising Star of Corporate Governance" by the Millstein Center in 2008 and was listed among Ethisphere’s "Most Influential in Business Ethics" in 2011 (no. 91) and 2013 (no. 77). He resides in Boston, Mass.