Declaration of Independence: How Independent Compliance Officers and Directors Can Hold Management More Accountable

In part 1, I talk generally about compliance & ethics, often through personal and professional stories and metaphors that illustrate important lessons I've learned over my 40-year career, from my early days at the Federal Reserve (before compliance was a well-known function) through my years as a chief compliance officer for some of the biggest companies in the world. My goal is to enlighten board members, as well as current, and especially, future compliance & ethics officers. We'll also talk about leadership do's and don'ts (the famous "soft skills" we hear so much about these days), as well as culture, behavior, and ethics. That's because, ultimately, compliance is all about human behavior. Whether you believe that people are inherently good or bad, human decisions are what drive corporate culture. And it's the culture that shapes an organization's short- and long-term objectives and successes.

In part 2, I'll go into greater detail about the compliance & ethics function and how it should operate in an enterprise-wide manner to be effective and sustainable for the long-run. In the last section of part 2, I'll lay out six recommendations-concrete, tangible steps that you and your company should take to restructure and/or strengthen your C&E function, not only to ensure more efficient implementation, but also to protect the company, its employees, its board, and, of course, yourself.

Some of these recommendations will be controversial and provocative. That's by design. This book is not only meant to prompt discussion, but also to be a catalyst for fundamental change. The status quo is broken and the root causes are not being addressed. The only way to change the culture-which, in turn will clean up organizations and protect our customers, markets, and society-is to call out those who need to be held accountable. If some feathers get ruffled in the process, I'm okay with that.