The correspondent wrote:
“In my job for the University, I am often alone in my efforts to convince the management and trustees of the system of the need for a comprehensive compliance initiative.
"In a presentation to the Trustees, I explained specifically about the FCPA ramifications of our international activity. I also submitted a formal proposal carefully outlining the needs, steps, rewards, penalties, and cost estimates. Unfortunately, funding is not forthcoming.
"It is hard to believe that an institution as large as the University does not have a compliance hotline, let alone a compliance program. However, your blog entry has inspired me to renew my quest once again.”
* * *
That feeling of “going it alone” is a common one for compliance officers. If you have felt this way, you are not alone (ironically). You might be too isolated, but you are not alone. An occupational hazard, the question is how to face it, unless it’s already dangerous or career suicide. No compliance officers must be a martyr to the cause.
So a suggested step one: Stay Connected. It’s critical to morale and to refusing to give in or give up. By the way, it’s not just us: Advocates for many good causes say the same thing.
Sharing your obstacles via a blog, as you did, connects COs to each other. Consider joining a compliance association or pioneer better-networked compliance communities wherever you live, like Guanajuato, Mexico, China or Anywhere USA.
In addition to morale boosting, other compliance officers usually have practical advice. In that spirit, here are three pieces of advice from me, and hopefully others will write in, as we all stick together:
- Asking an organization to launch a whole compliance program at once can be too much. It happens all the time. Run the risks and build on small steps, wherever possible.
- Have an ally-building strategy, in this case among students or faculty or one like-minded Dean. A recent boot camp for students generated interest and drew in local COs.
- Explain patiently but firmly using case studies what laws may be violated and the risks of prosecution. Though they wear the ‘halo’ of academia, universities are not exempt from terrible scandals or from regulations requiring compliance programs. Then you can explain the positives.
Thanks again for your letter. Though feeling alone sometimes, please stay connected.
Michael Scher is a contributing editor of the FCPA Blog. He has over three decades of experience as a senior compliance officer and attorney for international transactions. He is affiliated with ethiXbase, the owner of the FCPA Blog. He can be contacted here.