It is not often one can say with certainty that one event changed history but on this date in 1940 there was such an event. It was when Winston Churchill was asked by King George V to form a new government and become the Prime Minister of the United Kingdom. Churchill replaced Neville Chamberlain, who lost a no-confidence vote in the House of Commons on this date when Hitler invaded Holland, Belgium, and the Netherlands. Churchill formed a united front party, and quickly won the popular support of Britons. On May 13, in his first speech before the House of Commons, Prime Minister Churchill declared that “I have nothing to offer but blood, toil, tears, and sweat” and offered an outline of his bold plans for British resistance. In the first year of his administration, Britain stood alone against Nazi Germany, but Churchill promised his country and the world that the British people would “never surrender.” They never did.

One of Churchill’s great-grandson’s Jonathan Sandys teaches a leadership class based on principles from his great-grandfather, called Lead Like Churchill. I have had Jonathon on my leadership podcast 12 O’Clock High, a podcast on business leadership and he discusses leadership lessons from Churchill and gives people leadership pointers based on the career of Churchill. I thought about all this when reading a recent article in Harvard Business Review (HBR), entitled “What Sets Successful CEOs Apart by Elena Lytkina Botelho, Kim Rosenkoetter Powell, Stephen Kincaid and Dina Wang. The authors engaged in “a 10-year study, the CEO Genome Project. Its goal is to identify the specific attributes that differentiate high-performing CEOs (whom we define as executives meeting or exceeding expectations in the role, according to interviews with board members and majority investors deeply familiar with the CEOs’ performance).” They reviewed information to distinguish candidates who got hired as CEOs from those who did not and those who excelled in the role from those who underperformed.

There were four specific behaviors that they believe make for high-performing Chief Executive Officers (CEOs). This also means you can model your behavior towards these standards. Finally, if you feel you are deficient in any of these areas, you can take leadership classes to help development some of these traits. I found their research translated well for the attributes needed by a Chief Compliance Officer (CCO).

Deciding with Speed and Conviction

Great CEOs stand out not for being all-knowing and all-seeing but for being decisive. The authors noted, “They make decisions earlier, faster, and with greater conviction. They do so consistently—even amid ambiguity, with incomplete information, and in unfamiliar domains.” Interestingly, overly intellectual CEO types tend to go the opposite direction, being too deliberative and becoming bottlenecks for their organizations. A key consideration for any CCO is that there is never perfection or 100% information. Legally trained in-house lawyer types usually wait for more information before giving an opinion and the type of deliberation well-suited to a law department does not translate well outside a legal function.

Engaging for Impact

The role of any leader should be engagement, engagement and then more engagement. By understanding the needs of your key stakeholders and incorporating that into your solution or initiative you will have your team on board and ready to move forward. The authors quoted Madeline Bell, CEO of Children’s Hospital of Philadelphia “With any big decision, I create a stakeholder map of the key people who need to be on board. I identify the detractors and their concerns, and then I think about how I can take the energy that they might put into resistance and channel it into something positive. I make it clear to people that they’re important to the process and they’ll be part of a win.”

In a key insight for any CCO, the authors found that a leader must maintain composure. This is both the “Keep Calm and Do Compliance” insight from Jenny O’Brien and what the authors call “emotional contagion”. Even when receiving bad or difficult news, keep poker faced. Never let them see you see sweat and carry on. This extends out to tacking contentious issues. You must hear everyone out but if a risk is too great or a law will be broken, not everyone gets a vote.

Adapting Proactively

If there is one constant in compliance it is change. Whether that change be in the form of new information from the Department of Justice (DOJ) about Foreign Corrupt Practices Act (FCPA), a new product or service offering to a foreign government or state-owned enterprise, or simply changing business conditions; a CCO must always be adaptable. The authors found this to be a key indicia of a successful business leader. They cited to Dominic Barton, global managing partner of McKinsey & Company, who said, “It’s dealing with situations that are not in the playbook. As a CEO you are constantly faced with situations where a playbook simply cannot exist. You’d better be ready to adapt.”

Adaptability also means engaging in long-term strategy planning. By having a long-term focus, you can pick up on changes more quickly. You should also use a wide variety of tools to input data. For any CCO, this means that transaction monitoring can be a key tool going forward. Yet even setbacks can have a place in this hierarchy and are integral to growth. That is one of the reasons that I view every FCPA enforcement action as an opportunity for learning, growth and communication and blog about them as such.

Delivering Reliably

Jay Martin, CCO at Baker-Hughes Inc., continually reminds us that compliance is about execution. The same is true for leadership, whether at the CCO or CEO position. The authors found that the mundanity of reliability was a key indicia of success. Stakeholders want a steady hand and predictability. Even if you have stunning results, the authors found that Boards of Directors preferred a steady hand rather than huge results which may not be duplicated. Of course, setting realistic expectations are important but you must consistently follow through on your commitments. The bottom line is that no one in the corporate world wants surprises; certainly not negative surprises but there is even unease if a positive surprise is too great.

The authors conclude by writing, “leadership success is not a function of unalterable traits or unattainable pedigree. Nor is there anything exotic about the key ingredients: decisiveness, the ability to engage stakeholders, adaptability, and reliability. “While there is certainly no “one size fits all” approach, focusing on these essential behaviors will improve both a board’s likelihood of choosing the right CEO – and an individual leader’s chances of succeeding in the role.” The same is true for a CCO and if you would like to hold such a position one day, you should work towards incorporating these traits into your behaviors.


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

© Thomas R. Fox, 2017