We’ve all been grounded forever because of the you-know-what, and everyone’s patience is long gone. So I’ll skip the prelims and jump straight to the conclusion: Compliance officers must travel to do their jobs well. And here’s why.
First, compliance officers should live outside the region or country they oversee. In most of the world, subordinate employees, especially the younger ones, are deferential to their superiors and elders. It’s only in a few Western countries where this is not true. But where it is true — in Asia, the Latin countries, most of Africa — compliance officers who are minding the store in the community they’re from can be at a great disadvantage. It’s not their fault that they’re culturally inhibited. But it creates risks. (See, e.g., at least a dozen FCPA enforcement actions from China.) Is cultural deference something training, role-playing, and education can overcome? Sometimes. But to be safe, the better route is for companies to use a fly-in strategy for the compliance teams, rather than relying entirely on local talent.
Second, compliance officers need to meet the people they’re overseeing. Technology, as we’ve all seen during the lockdown, is fantastic. But it only goes so far. Can you take the true measure of someone from a weekly or even daily videoconference? Can you see deep into their character on a screen? Some people don’t like to appear on camera. They get nervous and shy, or too talky. They stutter or lose their train of thought. Yes, you can remotely see and hear them, but can you read them? A Chinese proverb supposedly says, “Don’t listen to what they say, go see.” That’s good advice. Look into their eyes, watch their hands, observe their breathing. Pay attention when they talk to others in the office, or take a phone call from a spouse, or order food at the corner shop.
Third, the people being overseen need to meet their compliance officer. In Russia, several people over the years told me they could never trust anyone who didn’t drink vodka. It wasn’t a challenge or a put-down. It was the truth and they wanted me to know it. My point is that unless people see their compliance officer in the flesh, there’s unlikely to ever be a bond of trust between them. Building that trust may or may not involve vodka, beer, wine, schnaps, ouzo, or sake. (Anthony Bourdain said, “Drink heavily with locals whenever possible.”) And it doesn’t mean everything needs to be done in person. Remote training works, as do long-distance check-ins by mobile phone apps, and so on. But unless there’s some facetime — the old-fashioned, in-person kind of facetime — the relationship between the compliance officer and those in the field will probably be formal, shallow, and unimportant.
Fourth, compliance officers must see the places where people work. Military strategists know that the map is not the terrain. Translation: Companies are more than budgets, sales reports, marketing plans, org charts, workflows, and headcounts. What’s the actual setting of the company’s operations, and how does the compliance program work or not work in that context? That means boots on the ground. Maybe the compliance officer just plops down behind a borrowed desk in Country X and sits there, with no announced agenda or departure date. Eventually, the wary locals will begin communicating. Someone will come by with a cup of coffee or sweet tea and . . . start talking. That’s the golden time for listening, and for learning what’s important. How the loading dock works. How family relations and histories influence the purchasing department. How office colleagues up and down the ladder relate to each other. What they think of the suits back at HQ. That’s the terrain, and compliance officers need to know it.
Fifth, travel makes compliance officers smarter, more intuitive, more empathetic, more observant . . . . OK, this isn’t a reason anyone should use in a pitch to the CEO about why the compliance department needs a bigger budget. But it’s true for most people that travel works a kind of magic. Mrs. Huston, one of my grade school teachers, told me travel enriches one’s reading life. Twenty years later I found out what she meant. And then some. It’s not that business trips are glamorous. They aren’t. There’s too much waiting and not enough doing. I remember the headaches and heartburn, the sore back and swollen feet. And yet travel opens the eyes of the soul, as the poets would say. Mark Twain more practically said travel is “fatal to prejudice, bigotry, and narrow mindedness, and many of our people need it sorely on these accounts.” I haven’t done or seen an empirical study about it, but I’ll bet compliance departments that travel see better overall performance and results. I’ll also bet the compliance officers who do some traveling are happier in their jobs and life. Just a hunch.
Compliance Officers in Western countries are employees too – with political incentives. This is why they good compliance programs (everywhere) have appropriate oversight and reporting.
Compliance Officers are not auditors or investigators, and should support the business, which requires local knowledge.
Do not agree at all with the first reason.
Sign: AML Compliance Officer from Argentina, Latin America.
I could not disagree more with the first point and, in my experience, it’s not even close. First, compliance officers are more effective when they live and work within, and thereby truly understand, the regions for which they are responsible. Ideally, they should be fully vested in those regions. Second, with all respect, the notion of “cultural inhibitions” among employees from regions outside of the U.S. and Europe is an outdated stereotype from the days when expats roamed the earth that, to the extent it was ever accurate generations ago, is better addressed in today’s world by offering world-class training and development opportunities to the talented women and men in Asia, the Middle East, Africa, Latin America and the rest of the world who aspire to become compliance professionals. This could not be more worth the time and effort. Genuinely global companies succeed by becoming “local” wherever they do business.
I respectfully agree with the comments above. A “fly in, fly out” approach to compliance is neither sustainable nor desirable.
Bourdain began with the proposition that people are fundamentally alike and everyone loves to eat well. His brilliance as a travel commentator was in using that universal truth as a foundation for empathetic exchanges with the people he met.
I like to think that fairness, honesty and respect are universal values too, and that’s the basis on which everyone in a global organisation can promote ethics and compliance. I certainly don’t think that compliance is a peculiarly Western discipline that “culturally inhibited” Others cannot master. If we think that or project preconceptions onto our colleagues, it’s us who are culturally inhibited, not them.
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