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Bad news. You’re promoted to compliance officer

[Editors’s note: This post is Part Four in a series about compliance officers. Part One is here, Part Two is here, and Part Three is here.]

In a prior post concerning the special role and risks of compliance officers, I criticized the way they’re lumped together with other employees instead of being recognized for the unique anti-corruption work they do daily.

But I made a similar error; I’d like to correct it now.

It’s not right to lump together all compliance officers. We have to recognize that those working in America are nearly on another planet from COs working in Asia, Africa, Latin America, Russia and many other countries.

While all compliance officers may be speaking the “same language,” the conditions of speaking truth to management or regulators are incomparably different.

If you are a CO outside America, this post is for you.

It’s a letter I received from a compliance officer, edited slightly to protect innocent parties.


Dear Michael,

Thank you for your post about the work of compliance officers.

The part about carrying the resignation letters really struck home. When the boss does NOT like you, he walks into your office and says: “Congratulations, you are promoted to compliance officer!” It’s like working in Police Internal Affairs, but without the gun.

When I read the CO and GC stories from the U.S., I sometimes miss the issue at first, because out in the wider world we’re dealing with whales and not minnows.

The level of misbehavior in Asia is tsunami like. I recall part of the New York Times Walmart Mexico story where the writer described how cameras recording a city council meeting were switched off to discuss Walmart’s business. I was impressed — they record city council meetings in Mexico? Wow. So people read that story and their eyes popped out. But I work in a continent where that level of bribery is the unremarked zeitgeist. It’s only when things get really out of hand that one notices.

Being a CO in Asia is particularly bad. I don’t know if there are instances of people being “bumped off,” but I was asked by several people if my street mugging was related to my work. The questions didn’t surprise me as much as it should, given how things are done out here. Take a look at the reporting in Fortune magazine about retaliation against lawyers and officers who objected to outright fraud at a drug company.

It’s relatively easy to make the “right” call when you are in a tough enforcement environment, where you may have actual personal liability, the people opposing you face similar issues and you have ethical duties to maintain, such as a law license. Tough calls are still tough, but conditions favor making them. When I read enforcement actions, I can tell the authorities have never lived or worked outside of the U.S. and have zero understanding of the cultural settings and pressures faced locally.

If you live in a slack ethical setting, where local customs don’t look on the same activity with moral approbation, family members pack the board, and your community standing is at stake, and the local authorities are complicit in activity — that’s a more challenging environment.

Good luck.

Sound familiar? Let’s communicate our stories — and then advocate for more “job security and working conditions” by talking about it in public.


Michael Scher is a contributing editor of the FCPA Blog. He has over three decades of experience as a senior compliance officer and attorney. His work for major companies in New York and the Middle East includes military procurements, international trade contracting, supervision of national sales forces and trainings for compliance with related laws, like the FCPA or AML. Miami-based, he assists companies in trainings and work shops and FCPA-related projects or investigations. In addition to English, he speaks French and Hebrew. Contact him here.

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