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‘No Compliance Officer should be a martyr to the cause’

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


“Dear Michael [the message from China said],
My name is FC. I have followed FCPA Blog for nearly two years, and have obtained extensive information and knowledge from the Blog.
When you answered questions to a compliance professional in China, I decided to write you an email and hoped you would give me some help and guidance on my career.
Since I graduated from University in China in 2007 (majoring in Finance and International Management), I have been working for the risk advisory industry at several major companies for six years in Shanghai.
I am very interested in due diligence and fraud investigation and doing researches and source inquiries, but I am also worried about my career path in the industry.  
First, the risk advisory industry is too small and risky in China. Only a handful of consulting firms operates in Shanghai. I hoped to work for famous risk advisory firms, but I did not get job interviews from these companies.
Second, the risk advisory services are risky, and are highly controlled and interfered by the local government. (ChinaWhys’ story really discourages me.) I sometimes wanted to give up and move to marketing research and strategy industry, but I really like investigations and hope to become a risk advisory consultant in the future.
I also wanted to study abroad to obtain a Master’s degree, but an MBA is too expensive to me.

I did not know which area is suitable in the risk advisory industry. Do you think programs in accounting or analytics are more suitable for my career development? Any suggestions?

Thanks a lot!  – FC”

My reply:
“Dear FC –
Thank you for your response to my posts and for your questions.
Your letter demonstrates why COs and related professionals, like investigators, need LOCAL networks to help each other, with support globally from COs, compliance professional associations and international organizations.
From far away America, we watched with shock and astonishment the televised arrest and “confession” of the investigators at ChinaWhys. They reportedly had excellent reputations and a long resume of legitimate investigations.
You are concerned about staying in the field where such things actually happen. How can due diligence be done by you and others if you might be arrested someday? This is not only a question of career building but a policy issue for China, and for COs in London and around the world.

It would be a loss for anti-corruption and to law and order if you leave: How will firms obtain due diligence on third parties in China if professionals like you leave the field? You have the desire for an MBA and mentoring by the best firms. If the compliance field is going to grow, and if COs and professionals are a key component of making global business more responsible, we can’t afford to lose good candidates. Compliance associations, international anti-corruption organizations and local networks of COs could do more to join forces and bring recognition to specific needs and “working conditions” of compliance professionals.
On the other hand, you have a life to lead, a career to build and a family to support. It’s a “stay or go” decision. Should you stay in a publically valued field that you like and suits your talents, or go now, before getting in more deeply? If you “sometimes wanted give up and move to marketing …or strategy,” I, for one, think it’s a fair question.
No CO should knowingly be a martyr to the cause. If you cannot see a personally suitable career path, and if you cannot see how to exit if the work turns dangerous, then go now. You and your family come first. Think about that option carefully; take to lunch anyone who can give you insights on where the field in China is going. As your kind letter suggests: Our lives are bigger than our careers.
With respect to you specific questions about career guidance for MBAs or programs, I will answer in a private email. If readers have suggestions, they can send them to me by email, and I will forward them.
Finally, whether you “stay or go,” I hope you will write for blogs, build networks, and advocate for changes to make the COs life and anti-corruption work safer and effective. Indeed, in another sense, our lives are bigger than our careers; you are entitled to challenge the status quo and to shape the world.

Good luck and thanks again for writing.  – Michael Scher”


I welcome advice for FC or comments on my reply by emails to me or in the comment space below this post.


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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