Compliance Today – December 2022
Having a solid understanding of the challenges our operating units face provides tremendous perspective for the compliance team, enabling it to more fully understand and assist with designing solutions for critical compliance risks. The most common approach to gaining this perspective is through regular meetings and other communications between compliance and each unit that has ownership of various compliance risks. Establishing and nurturing relationships between compliance and operating units is critical not only in getting a better understanding of risks, but also in designing practical solutions that are met with buy-in from the affected units, resulting in an ongoing partnership. In organizations with sufficient capacity in the compliance department, designating one of the team members as the compliance liaison with each unit can further enhance these relationships.
But another approach can add even greater perspective, and it’s an approach I think continues to be underutilized in the compliance profession—having business unit personnel do “rotations” with the compliance department. The size of an organization impacts whether this approach is feasible, but when it is done, the results are usually very positive. This is something that has been done more extensively in the internal audit profession, where employees from business units serve terms ranging from one to three years in the internal audit department, bringing crucial practical knowledge of how things operate into the daily business of the internal audit team.
Instead of gaining perspective through periodic meetings with operating units, think of how much more could be achieved by having personnel from those units embedded within the compliance team daily. The value of this practice can be incredible.
I’ve seen this work very well for several compliance teams, and a recent experience is what compelled me to write about it. I recently returned from the Federal Bureau of Investigation (FBI) Compliance Academy, cosponsored by SCCE & HCCA. This marked the first time we were able to hold this popular academy, organized by the FBI’s Office of Integrity & Compliance (OIC), since 2019 due to the pandemic. One of the many characteristics of the OIC that impressed me is the inclusion of two special agents in the office. This is done to provide perspective to the compliance team as it works with the various units within the FBI.
Perspective is a vital aspect of compliance work. Anything we can do to increase that perspective will, more often than not, help us in our work.