Recent reputational scandals have thrust corporate compliance into mainstream conversations around water coolers and in break rooms worldwide. The revelations about Volkswagen’s purposeful manipulation of software to circumvent emissions requirements underscores the importance compliance plays in day-to-day operations and how it must be moved from the “back-office” to the “front office.” Wherever the pieces ultimately fall for Volkswagen, compliance will need to be a core component of every decision the company makes as regulators, investors, customers, media and “watchdogs” analyze each move, potentially for years to come.

This provides the only path to redemption for Volkswagen, and offers a lesson for organizations to reevaluate their compliance program and focus on transparency. Organizations, especially those in highly regulated industries, must implement strategic business-centered processes that transcend compliance and incorporate risk mitigation into every aspect of their organization.

To establish, or reestablish, a strong ethics and compliance program, organizations should provide their compliance teams:


  • True and direct access to all levels throughout the organization
  • Sufficient and genuine (vs. check the box) support from senior leadership and the board
  • Visibility – bad things hide in dark places
  • The ability to influence and make real change
  • True accountability (vs. responsibility without true power)
  • Proactive, sustainable programs
  • Compensation aligned to doing the right thing vs. simply hitting quarterly numbers

Outright conspiracies and fraud are hard to combat if they are pervasive within a company. But the bright lights of compliance often tease out issues before they develop. The best foundation for this kind of transparency is to truly empower compliance and risk executives – with potentially a separate incentive and reporting process – to make sure companies live up to their code of conduct and ethical platitudes.

Compliance officers and risk mitigators must be business leaders, as well as project managers and process engineers. These skills enable them to at least stay on top, if not ahead, of regulatory change management. With a deep understanding of the organization, its processes and technologies, compliance officers are positioned to persuade management to create and maintain a holistic compliance and risk-mitigation program, while making it both a front-office priority and a best practice.

This post was written by Dave Curran, global director of Risk & Compliance at Thomson Reuters. Curran works with clients to help address and mitigate systemic regulatory, compliance, risk and related challenges both as a senior executive and lawyer who has deep experience at the intersection of business, law, technology, compliance and risk management, and preparedness. He has been on all sides of regulatory change – as general counsel/chief compliance officer, advisor, counselor and technology services provider – and has helped many companies navigate the complex waters of regulatory change through technology-driven process improvements.

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