Tone at the Top - Culture of Compliance

A panel of industry leaders and experts discuss the culture of compliance. As Chief Strategy Officer for CCO Tech and Co-CEO of Global Rhino (an affiliated company), I had the privilege of speaking on a panel at a national compliance conference with three esteemed industry colleagues, two in-house CCOs at asset management firms and a consulting expert in the hedge fund space.  As a panel, we focused on “Tone at the Top - Culture of Compliance.” Through decades of experience in financial services, I’ve learned a lot about modifying, tweaking, and enhancing compliance practices to most effectively impact the corporate culture. Here are my top ten takeaways:


  1. Customize Communications - Communication is only effective if your audience is listening to your message.  Know your audience and tailor the substance and tone of your message to cross the barriers that often arise in organizations.  Take into account employee-level, position, and demographics as appropriate. A busy executive may want a quick summary, a newer associate may relate better to a blog post. Meet them where they are and the message will be better heard and received.

  2. Document Positive Activities - As you communicate, make sure you take credit for sharing useful knowledge with your colleagues (maybe even position it as “training”), document the types of regulatory updates and practical tips that you apply to your compliance program, and save written records of review and changes to show to regulators when the time comes.  This helps evidence your culture of compliance by creating a visual and tangible story of your firm’s operations.

  3. Build Strong Internal Relationships - Getting to know your colleagues and developing a trusted relationship is critical in ensuring two-way communication; you don’t want to start that relationship when the chips are down or when a project is heading sideways.  Establish credibility early in your relationship, listen to your colleagues, and keep their confidences. Ultimately you want to become a trusted advisor to your colleagues. When they trust you, they will come to you early, which eliminates surprises that might catch you off guard. Like all healthy relationships, wholesome routines that promote prevention are better than rapid responses that address the symptoms of an issue.

  4. Get Invited to the Table - Establishing relationships is the first step to getting invited to the table, whether that table is lunch with your peers, meetings with your clients, or discussions with regulators.  The sooner you are involved in a kick-off meeting or a product development brainstorming session, the easier it is to provide helpful feedback before everything is set in stone. No one wants to say “no” at the last minute, so help the team early to ensure a successful launch.

  5. Understand the Business - The better you know and understand the business, the more insights you will have in how to create a win-win situation for all stakeholders.  You can identify alternative paths to get your colleagues, clients, or others to their end game within the parameters of the complex regulatory environment.

  6. Embed Compliance into the Business - Compliance should not be considered separate and apart from daily operations but should be embedded into the business and the overall corporate strategy.  Compliance is not an ivory tower function reviewing after the fact. Instead, it should be a way of life for every person in the company not only due to legal and regulatory requirements but because it is the right thing to do for everyone from top to bottom.

  7. Walk, Talk, Email - When addressing an issue, think about walking down the hall for an in-person conversation first, next consider picking up the phone, and only as a matter of last resort use email.  Most issues can be resolved more quickly and painlessly with a candid, in-person discussion.

  8. Build Extensive External Networks - Make sure you are not alone on an island.  Develop external resources through networking groups so that you can share best practices and learn from others.    

  9. Understand How Compliance is Good Business - Good compliance is the foundation for good corporate culture, which as a result leads to employee retention, client retention, and high performance.  Asset management firms are being selected these days using a combination of both performance results, ethics and integrity.

  10. Pace Yourself - This is a marathon, not a sprint.  There will be good days and more challenging ones.  Invest for the long-term and you will end up setting the tone at the top!

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