It is a rare person who is recognized as the best there ever was in a task or sport. The New York Times (NYT) reported on the death of Lones Wigger Jr., who won three Olympic medals in rifle shooting. He was a member of both the US and International Olympic Halls of Fame. Yet some of the most incredible comments came from his competitors and colleagues. In his obituary, Frank Litsky cited to two-time Olympic medalist Lanny Bassham who stated, “How do you define ‘The Best Ever?’ Would you add up the total medals won to see who is on top? Would you add up the total number of years he has dominated his sport? Would you take a survey of everyone who has been his competitor, to determine who received the most votes? Would you look at the number of national and world records held?” He answered his own question with “Not only is Wigger the only name at the top of these lists; no other shooter even comes close.” He also points towards greater productivity in compliance.

While not many can lay claim to being the best compliance professional, we all can strive to be the best compliance practitioner we are capable of being. I thought about that concept and Lones Wigger Jr., when I read an Inc. article on productivity by Leigh Buchanan, entitled “Want to Be More Productive? Follow This Advice From Tim Ferriss”. It has some interesting ideas for every Chief Compliance Officer (CCO) to consider in 2018 to improve productivity. One of the key insights is that with more free time a leader can “concentrate on complex, open-ended issues such as strategy, innovation, culture, motivation and vision.” If you as a CCO have more time to concentrate on those areas you will be able to consider not only where your compliance regime is, where it may be going and to where it could go. Another insight was that personal productivity does not equal compliance program progress.

Now consider this concept in the light of the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs, released in February 2017. The nature of operationalizing is to push your compliance program out into the business units as a business process so that your organization is doing compliance at the field level. By doing this it frees you up to take on more strategic tasks. While doing compliance in the field may not be as initially efficient as being done by the corporate office, the long-term benefits are not to be denigrated.

Delegation is always a key technique in improving productivity. However, you should not simply “shove things off your plate” but use the opportunity to give specific and new challenges to employees to help in their own career development. Think of how you can achieve dual goals of greater productivity and employee engagement/development by using the well-worn technique of delegation. Further, think of the cost effectiveness and the added benefit of Human Resource (HR) engagement.

An interesting point is to be “the master of no”. This is not the CCO as Dr. No from the Land of No. Here Buchanan means that you do not have to accept invitations and requests to participate in all projects. Make the project sponsors explain not only why they want your participation but more importantly “why your participation will make a difference.” Most lawyers are not good at saying ‘no’ to new work. Yet Buchanan makes the point that as a leader, you have to moderate some of your time to projects that not only benefit yourself and compliance but those where you can make a difference.

Engage with your customer base to get their views on your productivity. You should consider a survey of your customers, the company’s employees and third parties, about how they view your productivity. Of course, you have to listen to it and then remediate if they identify problems, issues or concerns. Once while working in the corporate legal department, we put out an annual survey to our internal clients but it was just for show to try and make believe we actually cared what our internal clients thought about our service. But if you are serious and want to use the feedback to actually improve, the power of sharing this issue with your constituent base can be quite powerful.

Another technique is to get out of the weeds and think long term. Arnold & Porter partner Stephen Martin still talks about a one, three and five year plan for your compliance program. Map that out so you can see where your compliance program should go, what is feasible and where technology could take your program. Not only will it give you a road map but you should be focused on what your company needs and how you will get them there. This one is sometimes difficult for the compliance practitioner who has worked more on the front lines, in a tactical rather than strategic role.

Engage with your direct reports and their direct reports; then move outward to more fully operationalize your compliance program. Operationalizing your compliance program means moving it down into your organization. The effect will improve your productivity as a CCO because others will take the lead on compliance and make it their own business process. This does not mean you need more meetings, it means you delegate out and make your team and employees accountable for following through with the required actions. You can facilitate this action with such positive strategies as a brown bag lunch or town hall.

You do not have to take this as far as Tim Ferriss did in The 4-Hour Workweek but having more time does allow you to focus on bigger and better types of compliance programs. It also allows you to consider where compliance may be headed in 2018 and beyond. Just as risks seems to be exploding; legal, financial, reputational and a host of others; Boards and senior management will look more and more towards the compliance function to use its risk management strategies and techniques to manage them. Make sure you have the time to not only be prepared but to do so.


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© Thomas R. Fox, 2017