Effecrtive Leadership in ComplianceI am one of the firm believers in the evolution of the compliance profession. Long gone are the days when the General Counsel (GC) could adequately perform both the GC that and Chief Compliance Officer (CCO) roles. Structurally the roles have become so large in multi-national, multi-billion dollar organizations, it is difficult to have one person do both roles adequately. Moreover, strategically the roles have very different focus with the GC’s role to protect the company and the CCO’s role to find, fix and remediate issues and problems.

In a recent blog post, entitled “What is Compliance Experience?”, SCCE President Roy Snell discussed the myriad of skills needed in the compliance discipline. His list included talents as diverse as “audit, education, risk, legal, investigations, ethics, policy development”. To Roy’s list I would add one that lawyer’s are sorely trained for, that being leadership. This is not something taught in law schools or given much acumen in law practices. Guidance in corporate training for lawyers in this skill is also sadly lacking. As a former GC who has moved into the compliance discipline I can attest to all the foregoing.

For this reason, and indeed a myriad of others, I am pleased to announce I have published my latest book, Effective Leadership Skills in Compliance: CCO 3.0 and Beyond, which is designed to provide the compliance professional with both tactical and strategic leadership skills to help navigate the host of corporate disciplines involved with the compliance function in the this modern era.

Over the past few years I have provided the compliance practitioner with solid information that can be used to implement, review and enhance a US Foreign Corrupt Practices Act (FCPA) or UK Bribery Act based compliance program. I have written several books that provide you with information that can be used for the nuts and bolts of compliance with a goal of providing the specifics of best practices for an anti-corruption/anti-bribery compliance program.

My new book moves beyond the technical aspects that a CCO or compliance professional must master to have success in their field. I aim to provide solid guidance about the non-legal, non-technical skills needed to move past CCO 2.0 to CCO 3.0 and beyond. This is the landscape where the truly outstanding compliance professional will move to make compliance a part of the everyday DNA in the manner in which a company does business.

Just as the understanding of anti-corruption and corresponding compliance programs have evolved, the CCO and compliance practitioner position will continue to evolve. This book provides you with the tactics and strategy to advance your own professional skills so that you will become one of the most important components of any business moving forward. For failure to move compliance into the very fabric of your organization, whether you manufacture cars in Germany, are a large multi-national retailer, extract minerals around the globe or simply do business in China, puts your company’s reputation at risk in a way that cannot be measured or even foretold.

I break the book down into three general areas for discussion. In Part I, I discuss communication skills that you need to be an effective CCO. I review areas as diverse as incorporating the concepts and tools of social media into your compliance program, the conversation that all true leaders engage in and how to just say no and the power of that word. Finally, I review the always difficult issue of culture across the globe and how you can communicate across cultural boundaries in a multi-national organization.

In Part II, I investigate several techniques, which you can use to put innovation into your compliance program. There are two disciplines that are not associated with the compliance profession that I believe can help you to think through innovation for your organization: project execution and design thinking. Another area for innovation and even inspiration that you can turn to in your own organization is the supply chain (SC) so I explore how techniques in this area can help you move the ball forward. I conclude Part II with some thoughts about how you can not only drive compliance into the fabric of your organization but also even burn compliance into the DNA of your company.

In Part III, I review the always significant area of influence. I consider how you should manage both up and down the organization and use empathy in your compliance practice. I talk about managing talent in both your own compliance department and the company as a whole. I even drill down into the weeds, tactically speaking, by providing some thoughts on that bane of corporate existence, never ending meetings by including a section on how to run a more efficient and effective meeting.

As the compliance function matures, the roles called upon by the CCO and compliance department teams will continue to both expand and grow. The worldwide explosions of corruption scandals, best exemplified by Volkswagen (VW), will put more pressure on corporate compliance functions to be prepared to respond to persons and groups as diverse as the Board of Directors to the Chief Executive Officer (CEO) to regulators, shareholders and even the public. The skillset needed for this most important role will continue to grow as well.

As many compliance practitioners came out of a corporate legal department or have a law school background, they traditionally have received very little training on how to lead. Knowing the answer or going to look it up and then writing a well-crafted memo thereon was about as much leadership training as those persons received. However, in the second half of this decade, those legal-training skills are simply not enough to be effective in the wide variety of roles a compliance practitioner currently has and will have in the future.

To be an effective compliance officer, you have to embrace skills that you may not have been trained for academically. These leadership skills are required to move compliance into the DNA of an organization, it will take much more than the brute force used by most corporate legal departments. Persuasion, influence, and communication skills will be required going forward. After all the roles of compliance and legal are very different. A corporate legal department is there to protect the interests of a company while the role of compliance is to prevent, find and fix problems before they become legal violations. Put another way, the role of legal is to tell the truth and the role of compliance is to tell the whole story. These are different roles that require very different skill sets in today’s corporation.

Nonetheless there are specific skills, tools and techniques that you can use to move forward both the message of compliance and burning it into the fabric of your organization. I have laid out some of the tools that I believe you can implement at little to no cost to you and your organization. The role of the compliance function has moved from the structural change identified in Compliance 2.0, where the CCO function moved out from under the legal department to the a functional unit, to CCO 3.0 which advocates incorporating cutting edge communication tools, for example social media, the two-way discussions. Moreover, the workplace is evolving. As a leader, you will need to evolve your leadership skills to lead generations as diverse as the greatest generation, to baby-boomers, gen-Xers, millennials, and I-gens. Both soft skills and hard skills are needed. This book gives you the tools you need to move forward into the next era of the compliance profession.

To purchase a copy of this book on Amazon.com, click here.


This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2016