How to Succeed as a Compliance Professional
In my view, they need to have both leadership and management skills — which are often very different and sometimes inconsistent. Most compliance professionals agree that they need to be both leaders and managers to succeed. The questions become:
-Which set of qualities is most important?
-Can a compliance professional exhibit some or all of each set of attributes, or are they mutually exclusive?
Analyzing the sets together may to answer these questions.
Vision vs. Structured Approach to Achieve the Vision.
Compliance professionals need to have a “compliance vision.” Hamilton Lindley says, a recognized compliance officer, says that they need to be more like mayors than sheriffs. I believe it is possible to exhibit both of these skills at various points in the life of an organization’s compliance program. Unfortunately, compliance professionals are sometimes relegated to the role of a “cost center” or dubbed the “sales prevention department” by unenlightened higher-ups in the organization.
It is therefore incumbent upon the compliance professional, instead of other leaders in the organization, to define the compliance vision in the first instance. If a compliance professional is implementing a compliance program or a new policy, procedure, or process, he or she is often compelled to develop, independently, the vision of how it will work within the organization.
Once the vision is defined, the next step is to deploy the vision and secure its buy-in throughout the organization. Thereafter, the next step is to create a plan for achieving the vision. The plan should be written, realistic, and entail accountability for both the compliance professional and others who are critical to its success.
Character vs. Character.
High character counts for both leaders and managers. It goes without saying that if you do not exhibit consistently good character in all of your dealings (not just when you are meeting on compliance issues), you will not succeed as a compliance professional. I have one friend who quit her habit of parking in the visitors’ spots at her organization, even if she was running into the building for just a few minutes or it was after hours, because doing otherwise would send the message that she was committed to compliance only when it was convenient. In addition, it sometimes helps to “be a character” when serving in a compliance role. Approaching a situation with good humor can help minimize the stress when dealing with a compliance issue.
Ability to Thrive in a Crisis vs. Ability to Avoid Crises.
Identifying non-compliance is inconsistent with the widely held beliefs that “we are an ethical organization” and “we are good people.” Accordingly, instances of potential non-compliance can cause crises within an organization. There is usually much at stake for both individuals and the organization.
Successful compliance professionals will be able to take charge in a crisis, calm everyone down, and come up with a thoughtful workplan for dealing with the situation. But constant crisis management should not be a compliance officer’s primary or sole activity. Instead, he or she should endeavor to identify and remedy potential non-compliance before it reaches crisis level. That is the whole rationale for having a compliance program in the first place. It is also one of the core elements of an effective program.
Capacity to Delegate vs. Capacity to Accept Delegation.
One mistake that compliance professionals routinely make is to assume the burden for ensuring compliance throughout the organization. The correct role is to develop programs, policies, and procedures aimed at ensuring compliance. In this model, actual compliance with applicable standards becomes everyone’s job.
Compliance officers need to delegate responsibility for actual compliance across the organization. They also need to accept delegation. Inside and outside counsel and others often rely on compliance professionals to do such things as gather information, develop remedial measures, hold stakeholders accountable, and ensure that the elements of an effective program are present and working.
Optimism vs. Skepticism.
A healthy measure of both characteristics is necessary. Compliance professionals must be optimistic that their colleagues want to do the right thing, and that the organization’s leaders will support doing the right thing when something goes awry (and it will). There must be a level of trust. They also have to be optimistic that their efforts make a difference.
But they need to be able to engage in the critical analysis and healthy skepticism that the job demands. The elements of an effective compliance program are not premised on trust. Rather, they are premised on evidence-based accountability — the kind that comes from processes like auditing and monitoring. While compliance professionals must try to trust colleagues when addressing potential non-compliance, they should nonetheless verify compliance in questionable cases.
Conclusion.
Compliance professionals need to have many qualities to be successful. When someone asks you, “Are you a leader or a manager?,” the answer should be an emphatic “Yes.”
