In this podcast, we consider Conan Doyle’s second Sherlock Homes novel, The Sign of Four.  The novel was published in 1890 but the story is set in 1888. The story entails a complex plot involving service in East India Company, India, the Indian Rebellion of 1857, a stolen treasure, and a secret pact among four convicts and two corrupt prison guards. It presents the detective’s drug habit and humanizes him in a way that had not been done by Doyle to-date. It also has a rather happy ending as it introduces us to Dr. Watson’s future wife, Mary Morstan to whom he proposes at the end of the novel. It also introduces today’s topic of the innovation process.

The Sign of Four was an intricate tale with many strands woven throughout. I thought of this novel when reading the article entitled “Leading Your Team into the Unknown” by Nathan Furr and Jeffrey H. Dyer in the Harvard Business Review. The article is a good starting point to help a CCO or compliance practitioner help move a compliance function down into the DNA of an organization to make compliance a more standard process for operationalizing compliance through “A Comprehensive Approach to Innovation” which I have adapted for the CCO or compliance practitioner to facilitate innovation in the compliance function. 

  1. Generate Insights. As a CCO or compliance practitioner, you can push compliance boundaries just as dramatically by demonstrating a willingness to reimagine some of your organization’s most fundamental assumptions about products, customers, and business models. But it means getting out there and seeking input from those outside your direct compliance function.
  1. Identify an Important Problem. Give your team an opportunity to synthesize the issues. You will need to dedicate both resources and time for the process to run its course. I recognize that all corporate employees have a day job so you will need to set aside specific time for such issue identification. In addition to providing resources and time, you will need to provide your innovation team support by removing the inevitable organizational barriers, which will be thrown up in their path.
  1. Develop the Solution. Begin byconstructing a set of simple prototypes of many different compliance tools. Start with a visual representation, which could be just a drawing; next move to testing a minimum viable prototype with internal consumers of the compliance solution through the simplest, quickest physical version of the offering you can devise. Finally, pilot test the full-blown compliance solution with a wider audience, including trusted and integral third parties to your organization.
  1. Devise the Business Model. Finally, once you have worked out the offering, apply the same experimental approach to developing and testing the components of the business model, including approaches to implementation.

Concluding, there are multiple values to such an approach. First, you will have generated “insight value-that is, the insight into the unknown that comes from reducing uncertainty.” Second is the “option value-the option upon resolving an unknown, to pursue, alter, or abandon a course of action.” Third is the “strategic value” which is both the value derived by your internal compliance consumers but also that of all the knowledge you will have gained throughout the course of the project; what worked and what did not work and, more importantly, why.

If there is one over-riding theme that the Department of Justice has communicated over the years it is that your compliance function needs to constantly evolve. It certainly must evolve as the corruption risks your company encounters develop but also it should also mature as your compliance program grows and becomes more ingrained in your organization. Moreover, as compliance moves into its next phase and becomes the best practice of a well-run business, innovation will become more of a focus.

If you are looking for the top compliance training class around, the Compliance Master Class. If you would like information please email at tfox@tfoxlaw.com and I can forward you the agenda. If you would to register, you can do so here.

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