Don’t stop there: More reasons why compliance officers must travel

Having spent more than 40 years doing compliance work, I can add some reasons to the recent At Large column why I think travel is necessary.

One, the real miscreants will shunt your remote communications. You’ll end up talking to some person whose title sounds impressive but who is totally out of any corruption scheme. Alternatively, they will hide the corruption scheme in the lower tiers of the accounting department so that it is well hidden from the CFO and internal audit.

Two, there are almost always additional files kept at the local office. One may find interesting bits of correspondence with the customer or the local agent. There are also sometimes records of facilitation payments that merit review.

Three, ask the local staff if they happen to keep a news clippings file. If one can read the names and a few key words, there may be significant surprises, worth getting translated.

Four, golf is a wonderful sport. In several cases, I learned fascinating details from business people from other companies. They were interested to have a conversation with an attorney who was not under any obligation to investigate them beyond what they wished to say, and who had no reporting obligations to their own management. People who play golf almost universally speak English, often even between themselves. One does not have to be a great player, but must not slow the game down, and it is absolutely necessary to know the rules and the etiquette.

Five, training for third parties and their employees needs to be in their own language. I found that using a local attorney to explain the U.S. and local law in the local language produced very different reactions than my English efforts. Usually the cost of that was small. I needed to be there to resolve the policy questions and to take notes on the questions. The facial expressions alone were often worth the price of the trip.

And six, when at a distant location, at the first general meeting, watch the attendees carefully. Note to whom they look when sensitive topics are mentioned. That will show where to focus further. If there is a key person who does not attend, that may indicate an issue. People engaged in mischief frequently do not want to hear the potential consequences.