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Across our client base it’s fair to say no two organizations – and no two CCOs – are alike. But there are themes we see time and time again. All too often, when big decisions are being made, CCOs feel like they haven’t been involved. Or they’re only looped in at the end to “make sure the compliance ducks are in a row”.
These decisions could be launching new lines of business, hiring or firing, changes to operational procedures, client communication strategy or marketing initiatives – to name just a few.
Neglecting compliance early in the decision making process is a flaw that many organizations fall victim to, whether consciously or subconsciously. Why this happens is hard to say definitively. At organizations that don’t focus on building a culture of compliance, it may be intentional because the business feels like the compliance team will be a blocker to business plans. While it may not be malicious, business leaders may just think of compliance as an “after the fact” part of the business (which it often is because a lot of compliance work occurs after the work has been done). In reality, compliance touches almost every part of the business and thus should be deeply involved with the day-to-day ongoings.
Whatever the reason, I’m sure most compliance professionals can relate with the feeling of scrambling to catch up on a project or reacting to a decision that is well on its way to completion. Then, because they weren’t involved from the start, the input they provide can feel like trying to change the route of a train that is already at full speed. This can deepen the feeling held by many that compliance is a roadblock, and the next time an idea comes up there will still be hesitance to include them. They’re just going to “make things harder.” In reality, had the compliance professionals been at the table from the beginning, the organization never would have gone down those faulty paths.
If this is a problem you can relate to, we’d encourage you to take a couple of steps.
First, have a conversation with the leaders in other departments at your organization. Explain that building compliance into a process is a lot easier than changing a process to fit compliance after the fact. And that when the decision has already been flushed out by non-compliance employees, additional changes can be costly and create delay. Include specific examples of times you should have been involved earlier on, and how those decisions would have gone more smoothly if you were.
Most importantly, when you do get that seat at the table, make sure you aren’t that stereotypical compliance employee who is constantly telling the business ‘no’. You want to make sure you get invited back again, and unless there is a legitimate legal or regulatory issue with the specific item, you should try and work with the business to turn their ideas into reality while also building compliant processes at the same time.
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If you would like to talk more about how you can strengthen the culture of compliance at your organization, please do not hesitate to reach out.
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