I’m going to take an exam to be certified as a compliance professional on April 1. The exam is offered by the Society of Corporate Compliance and Ethics after the SCCE’s European Compliance & Ethics Institute in London.
I’ve started studying.
Why would someone with a law degree and decades of work experience in law and compliance sit for a compliance exam? Here are my top ten reasons:
Reason 10: Big Bucks. Chief compliance officer’s are knocking down huge salaries these days so maybe a credential is a path to the CCO position. Just kidding. I don’t advise taking any compliance job just for the money. Life would be miserable if you don’t love the work. It’s a mission-driven role and the workload is no laughing matter. But it is a growing field and a good place to make a career.
Reason 9. Humility. A lot has changed. Do I really know what compliance officers are expected to do? A dose of humility is good preventive medicine, because “humble is honest,” in the words of a compliance commentator who graces the masthead of the FCPA Blog.
Reason 8. Can I transition from law? Compliance is not lawyering. It’s a new profession. Donna Boehme, who bravely pioneered this new Compliance 2.0, wisely cautions lawyers to approach the transition with an open mind. See Reason #9 above.
Reason 7. A new body of knowledge. The exam is based on information gathered from working compliance officers. It’s new business organization knowledge. What do you need to know to set up and run a compliance program? What kind of business-side management techniques are ahead?
Reason 6. Who has the answers? For example, what should you do when the CEO says she needs a training program for all 10,000 managers of a global corporation to maintain an ethical business culture? I don’t recall from law school or law firm practice the answer or an analytic framework. However, I have read impressive answers while preparing for the exam. See the SCCE magazine archives here.
Reason 5. Should everyone get certified? Since I write about compliance, shouldn’t I be certified as a compliance professional too? Recently a group of big firm auditors in Brazil all took the exam. I’d like to participate in this trend and encourage it.
Reason 4. Compliance Code of Conduct. Lawyers have a code. It helps protect them from unethical choices and retaliation. Compliance officers should also have a code. They need protection from retaliation for refusing to go along with illegal or “lawful but awful” conduct. The SCCE Code of Conduct is covered on the exam. It’s available here (pdf).
Reason 3. Compliance is more than a program. I’ve argued on the FCPA Blog that compliance is not just a “compliance program” but a system of internal and external checks and balances that includes the media, prosecutors and global public opinion. And how about business side enforcement through collective actions widely recognized in Europe but ignored in America? I hope these topics are included in the exam. “Compliance” work should be defined broadly to support the personal and professional growth of compliance officers, and advocacy and innovation for this new profession.
Reason 2. Who are the new compliance officers? I’d like to meet the people who want to be certified compliance professionals. What’s their motivation? Is it the compliance mission, love of project management, a better career, being part of something new? After decades of scholarship and advocacy, the International Anti-Corruption Academy’s scholar and advocate Michael Johnston expressed a similar kinship to compliance officers.
Johnston wrote in the IACA Alumnus Magazine (March 2015 edition):
Basically, the most inspiring thing about (compliance) is just getting to know people around the world and how they are dealing with and experiencing these issues. I find that there are people facing terrible problems that we in the United States do not even think about yet — they keep at it and they stay at least somewhat optimistic. They’re willing to take risks to do something about the situation. … I think the real key is always trying to learn as much as you bring to the table.
Reason 1. After I pass (fingers crossed), then what? Do you think of it as only a test and now you’re done with it? Or are you motivated to participate in building this new profession? Does the process of preparing for the exam and taking it create an identity and new foundation for compliance work? If I pass the exam on April 1, I’ll report back.
OK, I’ll also report back if I don’t pass. See Reason 9 above.
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Disclosure: For the FCPA Blog, I’ll be attending the SCCE European Compliance &Ethics Institute in London from March 29 to April 1. The SCCE is waiving the attendance charge for me and providing a press pass. I’ll be paying other expenses that won’t be reimbursed, like travel, lodging, and the exam fee, and I am accruing no continuing education credits. Attendance at the SCCE conference is not required to take the exam or for SCCE certification. Certifications are offered by other worthy organizations.
Michael Scher is a senior editor of the FCPA Blog. He has over three decades of experience as a senior compliance officer and attorney for international transactions. He can be contacted here.