As most compliance professionals are lawyers with legal training, they have little actual experience with implementing new process-based projects. Russ Berland, Chief Compliance Officer (CCO) at Aventiv Technologies, LLC, has recommended that a CCO employ a professional Project Manager (PM) to implement new compliance initiatives. Yet an equally important question is when to begin a new compliance project?

I was therefore intrigued by a new Harvard Business Review (HBR) article, entitled “6 Questions to Ask Before Starting a Big Project, by Antonio Nieto-Rodriguez and Whitney Johnson, most particularly when the authors began their piece with the following, “Knowing when to start a project is a key factor to its success. And yet it’s a strategic talent very few companies have developed. If you begin a project too soon, chances are high that the project will miss its deadline — if it doesn’t fail outright.”

The authors listed six questions you should consider before beginning a new, large project. While some would appear to be self-evident, “deciding when to invest your company’s scarce resources in a project is of strategic importance. Yet, there is currently no management framework available to help executives or individuals with the vital decision of when the right time has arrived.” I have adapted their findings for the compliance practitioner.

  1. Has the project been done before?

Generally, this question relates to customers. For the compliance professional, whose clients are the company’s employees and third parties, it means finding a niche that can move the compliance program forward by more fully operationalizing compliance among the workforce. The newer the idea(s) the longer lead time you will need. For instance, if you are instituting a third-party risk management program for the first time, you will need a longer time than an upgrade to the program.

  1. Is the project part of your core business and will it leverage your strengths?

This means that mimicking other business process and adding on a compliance angle. It might also mean piggybacking on existing financial controls to provide a compliance component. For example, if you can use the lifecycle of Human Resource (HR) touchpoints with employees to create greater compliance and ethics awareness, you need less time to implement.

  1. Can you clearly define the scope? Do you know what the project will produce and look like when completed?

Under these questions most lawyers will fall short as they may well not have a good understanding of the final end product, particularly if it is a technological implementation. The authors spell it out as follows, “How many of the ultimate requirements do you know (1-100%)? If you have less than 50% clarity of what the project will deliver, keep exploring and iterating to better define the project. Traditional project management theory teaches us to have 100% of the requirements defined at the beginning of the project, but we know this is hardly the case. Aim at having 80%-90% of the requirements defined before moving to the full-blown project stage.”

  1. What is the investment cost?

While this might seem like a very obvious self-evident question, it includes determining what “resources will be required — financial, human, expertise, management time — and determining whether they are available in-house or will have to be sourced externally. Is this something we can and want to commit to?” The reality is there could be both scope-creep and mission-creep and many compliance projects may well cost more than originally planned. Further, this is not simply in the financial realm as many compliance projects can take up more time, resources and management time than originally planned or budgeted. The authors conclude this section by stating, “Therefore, it is important to clarify before starting the project who is going to pay for it, as well as ensuring the commitment of the resources, including time dedicated by executives.”

  1. Do you have buy-in from key leaders and the wider organization?

This might be the most obvious issue or question to pose because if you do not have senior management buy-in, you may be doomed to fail to start. Yet, it is more than simply senior management buy-in as the authors note, “Excellent ideas and brilliant projects have become monumental failures due to lack of buy-in from key stakeholders. The exploration phase should coalesce critical mass around the project, enhancing its viability. Are you getting buy-in from crucial stakeholders? Is there movement or inertia around the idea, within the organization? If the institutional will is there, the other necessary resources are likely to be in the pipeline.” This means that key stakeholders should also be on board with the project. It requires the CCO to get out and sell the idea behind the project.

  1. What is the timeline?

Once again this may seem self-evident but, as the authors note, “Projects that languish when they should be charging ahead are costly and unlikely to produce satisfactory results. Establish a timeline and a schedule for the achievement of necessary benchmarks. Tight milestones focus organizations and teams, so use them wisely. Be doubtful about timelines of projects that don’t spend time in the exploration phase.” You can build in some discretion but a project that seems to go on forever may well be perceived as a failure before you go live on Day 1.

Here the authors conclude that eventually there is a point “when it’s time to pull the plug on the idea or actively develop it. Resources should have been assembled, personnel emplaced, objectives articulated, and a timeframe established. The project begins after critical needs have been identified and addressed, not before. When a project launches, it should be ready to go”. If you must terminate a project, the best time to do so is before it has been initiated.

If you are considering a large compliance upgrade or investment, posing these six questions to yourself and answering them honestly could well go a long way towards your eventual project success

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, 2020