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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

How do you ‘market’ your compliance program?

Nothing sells itself, not even compliance. There’s always a process of presentation. So if we talk about “marketing” compliance, we’re not cheapening it. Instead, we’re trying to understand how compliance officers can be most effective.

At the risk of gross oversimplification, let’s say there are three ways for compliance officers to present their message: as enforcers, as protectors, and as value leaders.

What are the pros and cons of each?

As enforcers. On one level, compliance comes down to following rules. So compliance officers can fall naturally into the enforcer role. “We’re here to make sure no one pays bribes.” That’s a clear and simple message.

When compliance leaders don’t intentionally choose how to deliver their message, they’ll usually slip by default into the enforcer role.

Does the enforcer role work? Does it deter bribery?

Not so much.

No one likes it when institutional authority is lorded over them. That’s why there’s usually resentment toward enforcers.

Do people behave any better when enforcers are looking over their shoulder? No, they find sneaky ways to misbehave.

As protectors. Bribery scandals destroy brands and ruin careers and lives. So compliance is also about shielding the company and its people from harm.

Anti-corruption policies often warn about harm emanating from FCPA violations. So again, it’s natural for compliance officers to step into the role as protectors.

The desire to avoid harm, especially harm to self and family, can be a strong motivator and deterrent.

Most FCPA enforcement actions contain examples of corporate and personal tragedies. Telling those stories is a way to enhance the compliance message.

As value leaders. This is the compliance officer’s most powerful role and best way to market the compliance message.

Mad Men discovered nearly 50 years ago that portraying “the Pepsi Generation” sold more soda than telling people why Pepsi was better than Coke.

The pinnacle of marketing is showing people “a better version of themselves,” Zander Nethercutt said. Ask Apple, Patagonia, and Tesla.

Why shouldn’t the message from compliance be about values and aspirations?

My post describing “five reasons why you have an anti-corruption program” was primarily about values. I heard from many readers. You told me how important those values are to you. So, go ahead and share them.


In real life, compliance officers are usually some blend of enforcer, protector, and value leader.

But putting more emphasis on the values behind a message deepens its impact. And better yet when the messengers themselves embody those values.

Compliance officers have a great opportunity to show co-workers “a better version of themselves.” Nothing will do more to deter bribery.

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