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Do compliance officers have to speak English?

When you look at the numbers, the dominance of English as our lingua franca isn’t apparent. Out of the world’s total population of 7.5 billion people, about 1.5 billion can speak English, and just 400 million of them are native English speakers.

And yet, anyone who dips a toe into our globalized world recognizes instantly that English, and only English, is our common language.

Why English as the lingua franca? Multiple reasons. Some relevant points along the arc of history include:

The British Empire, international shipping, WWI, the oil and gas industry, WWII and NATO, the U.S. dollar and World Bank, Hollywood, McDonald’s, aviation and global travel, telecommunications, medicine and science, and finally, technology and the internet.

Suddenly (it seems), everyone needs a way to communicate everywhere with everyone else.

Almost by default, English is the way. It had a head start — it’s an official language for around 60 countries and more than 25 non-sovereign territories — it’s learnable in big or small steps, and it has absorbed enough foreign-origin words to be relatively precise.

It’s also a language that can be simplified and still be useful. As one writer said, we now have “Seaspeak, Police Speak, and Airspeak — simplified forms of English used every day all over the world.”

On top of that, there’s been little pushback. A letter-writer to the Wall Street Journal said,  “But there is nothing wrong with world-wide use of English. It bridges barriers and brings great advances. Someday, the world will move to another language, but for now, this is the English era.”

Even the Foreign Corrupt Practices Act is a force propelling corporate-wide adoption of English. With the FCPA’s long arm, compliance problems anywhere can be catastrophic, so a consistent approach to risk management is essential. The powerful UK Bribery Act compounds the need for English-speaking compliance officers.

So, what’s the downside of mandatory English?

Relying solely on English “inevitably limits the world’s collective knowledge base,” according to Rosemary Salomone, a law professor at St. John’s University School of Law. “Scientists and scholars who lack fluency in English are often frozen out of teaching, publication, speaking and networking opportunities essential to advancing their careers,” she said.

That exclusionary impact is felt strongly in the commercial world, where English is a hiring threshold. Those without English, no matter how otherwise qualified, can’t get a foot in the door. Who knows how many potentially brilliant compliance officers never get a chance because they can’t pass an English proficiency test?

To avoid that, some companies use language strategies. IBM was an early corporate adopter of English as its lingua franca. But the company identified eight other languages important to serving local markets, according to Tsedal Neeley and Robert Steven Kaplan.

“IBM hires global professionals with the expectation of strengthening their language skills through immersive training, private coaching, or online learning. Further, employees know that certain international assignments carry with them a language-training requirement,” Neeley and Kaplan wrote in 2014.

Do compliance departments hire non-English speakers with the expectation of strengthening their language skills? Or is compliance too sensitive, time-critical, and distant from commercial concerns to benefit from IBM’s type of language strategy?

Another downside to mandatory English is the loss of nuanced local knowledge. When everyone must use English, is anyone left who understands how culture might impact compliance?

The law prof from St. John’s, Rosemary Salomone, tells this story:

In 2010, Japan’s largest online retailer, Rakuten, announced that all employees had to take an exam to demonstrate English proficiency within two years or risk being dismissed or demoted. The majority of Rakuten’s workforce couldn’t make the cut, and by 2018, 80 percent of the new engineers in its Tokyo offices were non-Japanese. Some of those who remained claimed they felt like “expats” in their own country.

(Prof Salomone wrote a striking book about the downside of English as the lingua franca, published in November 2021 by Oxford University Press, called The Rise of English: Global Politics and the Power of Language.)

We could also talk about the over-Americanizing impact of global English, the inevitable gaps between native English speakers and those who learn it later, the growing cultural isolation of English-only speakers, or mistaking English proficiency for functional ability and competence, thereby degrading managerial performance.

Will another language push English aside? That will happen eventually, but who knows when?

What could take its place?

There might be clues. According to Prof Salomone, English is the most popular language online, used by about 26 percent of people on the internet. But, she says, Chinese isn’t far behind at 19 percent, followed fairly closely by Spanish and Arabic.

For now, however, the world’s common language is English. And, like it or not, English is the language of compliance too.

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