If you have not seen it, I would suggest you go to see what I believe is the summer’s top movie, Dunkirk. It is great cinema, good history and presents the view of soldier on the ground from the English perspective. It unfolds on land, sea and air; in decreasing time frames of one week, one day and one hour. I was lucky enough to see it in glorious 70MM wide screen so the resolution was outstanding. I do not think a spoiler alert is really necessary to tell you the British managed to evacuate nearly 400,000 men from certain annihilation. It may have begun as a disastrous retreat but it ended as a glorious victory which continues to inspire Brits today. As we were leaving the theater, my wife said it made her proud to be British.

There are several leadership lessons which I believe can be learned from the British (and German) experiences at Dunkirk, which was a series of battles, campaigns and events that lasted from May 25, 1940 until June 4, 1940. Obviously, Winston Churchill was the key English political figure in this entire series of events. While most remember his stirring post evacuation speech and apparent iron will to bring the British Army home to continue the fight, as with most of history, it was more nuanced than that simple narrative. The first thing Churchill had to do was navigate a War Cabinet made up of both Tories and Labour ministers where not everyone wanted to continue the fight. Some thought only a peace treaty or negotiation with the Germans would save England from the destruction wrecked on the Continent by Hitler. Churchill was able to move the War Cabinet to a position of resistance.

A Korn Ferry Institute piece, entitled “Dunkirk: What a Military Crisis Can Teach Us”, noted, “Beyond the entertainment value, however, business leaders may find some powerful lessons on the big screen: the importance of organizational agility in the face of a sudden turn of events; being decisive in setting forth and communicating a strategy; and, most important, having the courage to step up and lead in a crisis.” The piece went on state, “Business leaders may never face a crisis of the magnitude of a military battle or the life-or-death consequences of a plane crash. But they can learn lessons from how to emerge successful from urgent and dire events.” The article quoted Gerry McNamara, who said “It takes leaders who can communicate a vision—identify the problem and ‘take a picture’ of what results look like—what success looks like when the problem is resolved”.

Brian Dodd, in his On Leadership blog post entitled “19 Leadership Quotes and Lessons from Dunkirk, provided his thoughts on some of the key leadership lessons from the entire series of events. I found several of them important and I have adapted them for any Chief Compliance Officer (CCO) going forward.

  1. Smart Leaders Understand The Value Of Partnership – “He’s on me.” “I’m on him.” – Tom Hardy was one of a three-man squadron of British fighter pilots providing air support for the British convoy sent to evacuate the troops. Of the three, one was shot down, one ditched in the Channel and Hardy’s plane ran out of gas, landed on the beach where he scuttled it and he was captured. For any CCO, you should partner with other corporate functions and disciplines to accomplish anything.
  2. Smart Leaders Always Create Options – “Many of the soldiers on boats positioned themselves with an escape route if bombed. This would allow them not to become trapped below and drown.” This is the antithesis of Elizabeth Holmes, Chief Executive Officer (CEO) of Theranos, who famously said if you have a Plan B, you have already failed. In the business world, as in combat, you must have a backup plan as the business situation is never static.
  3. Passivity Is Not a Leadership Strategy – Mr. Dawson noted, “There won’t be a home if we don’t get our men across the Channel.” This is most clearly borne out in the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation) which focuses on the operationalization or doing compliance. As Hui Chen has noted, the Evaluation is designed to get companies to ask questions about their own compliance program and incorporate the answers into the decision-making calculus going forward.
  4. A Leader’s Greatest Ability Is Their Availability – Mr. Dawson’s son said, “We have to pick up survivors.” He then noted, “To do that we must survive ourselves.” Fortunately for the CCO the business equivalent is not so drastic. However, it does bring up the larger truth that to be successful you need to get out of the office and into the field to meet your troops, whether it be your compliance team or your employee base.
  5. It Takes Everyone To Survive Times Of Desperation – In the English version of the Alamo, hundreds of average citizens sailed their private vessels to Dunkirk to rescue soldiers and get them safely back to England. Chuck Duross once referred to the compliance profession as a company’s “Alamo” to which I gingerly responded that everyone was slaughtered at the Alamo. However, that was not true at Dunkirk and even if a company has sustained systemic compliance violations at the C-Suite level, the company can make a comeback by stepping back and following the requirements under the FCPA Pilot Program.
  6. Ordinary People Have the Capacity to Do Extraordinary Things – Ordinary people used their personal vessels to rescue the soldiers. One of the greatest parts of the Dunkirk story was the response of the ordinary Englishmen and women who responded to the call for boats. Yet these boats largely ferried men from the beaches out to large transport ships moored in deeper waters and did not ferry the men back to England. The is the role that many corporate employees can play for any compliance function, doing their jobs to operationalize compliance.

Given the sad state of current Hollywood movie-making it may not seem a stretch to be the summer’s best film. Yet Director Christopher Nolan made a devastating war film without cursing and without undue gore, all the while communicating the horrors and terror of the individual soldiers at Dunkirk. It is worth it for that accomplishment alone. But also consider it for the leadership lessons you can learn.


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, 2017