In the black-and-white world of Compliance 1.0, compliance officers labored alone, emerging now and then to nag the sales force about sticking to the rules and staying out of trouble. The sales people and others spent a lot of time pointing fingers at compliance — the Department of No, the Division of Sales Prevention, the Anti-Profit Police.
Fast forward to the Technicolor world of Compliance 2.0. Today compliance is all about staying connected. If you lack the willingness to get connected, you can’t do the work. Compliance 2.0 means sharing and collaborating to solve the hardest corporate problems. Only teams can run innovative global business systems and think about the broader community welfare.
Today’s compliance professionals are sharing what they know within their companies. And outside, they’re pooling their collective knowledge and tapping into new resources — membership groups, conferences and workshops, publications like the FCPA Blog and others, and social media message boards.
Compliance 2.0 means collaborating with legal, HR, audit, risk management, and others. Testing internal controls means involving professionals from across the corporate body. We need the folks from sales and marketing to trust us enough to share strategic plans. That’s how we can help everyone plan ahead. We need to convince allies in the C-Suite that business units with a good compliance performanc deserve incentives.
Compliance 2.0 professionals can’t fly solo — and why would we want to? The old days of grinding it out alone against indifferent executives and hostile, turf-defending divisions were never fun or rewarding, and often ended with a humiliating pink slip.
When the FCPA languished on the books unprosecuted, compliance looked expensive and unnecessary. But enforcement has exploded and expectations among global prosescutors and regulators have helped create Compliance 2.0. That’s why compliance is now seen as a smart and essential investment, a core business competency.
Compliance officers aren’t alone anymore. They’ve come in from the cold.
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.