As compliance professionals, we all have to face scarcity, in particular scarcity of resources. If we want to make our compliance program work, we need to be creative and make the most out of what we have. That's where the commando approach to compliance comes into play.
No matter how well we end up mastering the art of constantly influencing the decision makers to make sure they give us what we need (read: 3 Steps to Get Every Department Excited About Compliance), it is still highly unlikely that headcount on our team will be tripled overnight.
While we work on getting resources on the mid-term, let’s make the most of what we have. Here are a few commando tips to build the best team, deploy smart strategies to increase it seamlessly, and the secrets to keeping your wonderful team motivated over time.
Let me tell you, that the latter is a subtle balance, somewhere between avoiding overburdening your team with boring administrative tasks and providing a strong sense of purpose.
But first things first, we need to get the foundations right.
1. You Have a Limited Team: Build it Right
Never Be Afraid to Hire People Who Are Smarter Than You
This advice was once given to me by one of my most inspiring bosses, could not be truer. Smart people on your team will just make you shine even brighter.
Don’t Recruit People Like You
Early in my career, I had the opportunity to recruit an apprentice to help me deploy a communication plan for compliance. During the interview process, we immediately clicked as we were extremely similar. A bit too much. As a result of such like-mindedness, we shared the same qualities and the same shortcomings. It did not take long for me to realize this duo was not the best fit to get things done and bring value in the best possible way. As a more experienced colleague put all that wisdom in one sentence over coffee “always hire people who are not like you”, I realized I had fallen for this unconscious bias trap. My advice is that you know your strengths and weaknesses well, and your preferences (detail & technique, the big picture, etc.) and that you try to find the opposite in your new hire. If you don't really know what your preferences are, try the MBTI Test, it will give you a good idea. Focusing on finding somebody who strengthens your weak sides will bring you a fresh perspective and a broad basis to build and deploy a solid compliance program.
Tap Into All Types of Expertise
Compliance will not thrive based on strong legal expertise only. As you have the ability to grow your team, make sure to tap into the following resources and know how: project management, internal audit, communication, finance. They will adequately complement your legal skills and bring you a new perspective.
2. Work to Keep Your Team Motivated
The first structural point is to avoid overwork & administrative burden – it kills creativity. You want your team to think out of the box, create processes that make sense and spot risks. This can only be done with a fresh mind. Most importantly, you need your team to focus on what really matters, and not squander their energy on nitty-gritty administrative tasks. I know that we are all overworked, but what if we start to approach our day differently.
Are you really putting the most adequate resources in front of a given need? To be sure of that point, I recommend you regularly undertake a consistency check: list all the business needs, the compliance tasks that are performed by your team, their frequency, who handles it today and how you can allocate it better to carve out some time to focus on what really matters. See below an example. I promise this is time well spent!
|Business Need||Task Required by Compliance Team||Importance||Complexity||Who Handles Today?||How We Could Handle It Tomorrow|
|Do business with reputable partners||Due diligence on business partners:||High||Medium||Senior Compliance Counsel||Automate information collection|
Involve business team to conduct an initial risk assessment
Business team to contact the third party
Business team to prepare the file for compliance
Senior compliance to review file, check screenings (false positives) and issue a recommendation
In conducting the exercise, don't forget to think that getting things done does not necessarily mean getting them done by your core team of sustainable resources.
Make the Most Out of Consultants, Trainees, and Interns
In most companies, it is by far much easier to get an intern or an apprentice than a full headcount. Make the most out of that possibility. This does not only allow you to spot talent early and retain them, but also to intelligently create a business case for your next sustainable hire. By hiring a trainee or apprentice, you create a new steady stream of work and thus you put your foot in the door to get a more sustainable resource once the trainee has to leave: “but who is going to do XXX now?”
Make Other Departments Work For You
Implementing a compliance program is about managing a global project that involves various stakeholders in the company (again, read: A Commando Approach to Compliance: Steps to Get Every Department Excited About Compliance).
Make sure each stakeholder does its part. Outsource as much as you can to allocate roles and responsibilities accordingly. Are you implementing a new third-party management process? Make sure that your team does not end up filling the initial internal risk assessment questionnaire: it should be the business manager in charge of the relationship: not only is it healthy, it also adequately sensitizes operational teams to compliance.
More generally, never let your team be the pen holder for other functions which know better. They have better things to do to create value.
There are certain tasks that machines do better than humans. You don’t want your precious and limited teams to handle the administrative burden of documenting compliance, sending emails, reminders, collecting manual signatures, filling excel spreadsheets, calculating statistics from an office folder and 25 excel spreadsheets. The more processes you have and the more data your process, the more sense it makes to automate all you can. This will not only help your team get new skills and face new challenges such as implementing an exciting IT project, but it will also give them pride and visibility throughout the company.
More importantly, your type of leadership will matter. You need to lead your team with a strong sense of purpose.
3. Let’s Talk About You: Be an Inspirer, Not a Manager
“It doesn't make sense to hire smart people and tell them what to do; we hire smart people so they can tell us what to do”.
This overused quote from Steve Jobs is very much on point. You don’t want your team member who awaits your instructions to take any action.
Trust that your team will come up with creative solutions and give them space to think freely. Make it clear to them that this is what you expect.
On your end, be ready to drop the ego as this also means being challenged in the way you think things should be done!
In some of the most innovative companies, such as Google, employees have a day to work on whatever they think makes sense. Try to implement a mini ‘Google time’ within your team. Maybe a day per month? I can only recommend that you do the same yourself!
This is all about giving your team a sense of purpose and vision. Money is not everything. The famous principle “If you give peanuts you get monkeys” is true only to a certain extent.
As Dan Pink puts it in an inspiring Ted Talk The Puzzle of Motivation:
“In a ROWE [Results Only Work Environment, in place at a dozen companies in America] people don't have schedules. They show up when they want. They don't have to be in the office at a certain time, or any time. They just have to get their work done. How they do it, when they do it, where they do it, is totally up to them. Meetings in these kinds of environments are optional. What happens? Almost across the board, productivity goes up, worker engagement goes up, worker satisfaction goes up, turnover goes down. Autonomy, mastery and purpose, the building blocks of a new way of doing things.”
I hope this inspires you to do things differently to keep your precious compliance team motivated.
A Commando Approach to Compliance
In case you didn’t catch the introductory post, Key Compliance Challenges from the Field: Meet GAN’s Newest Expert, I wanted to fill you in on what ‘A Commando Approach to Compliance’ is all about. In short: it is a blog series that focuses on the very concrete challenges compliance officers face in their day-to-day lives. The commando aspect of this title refers to the diligent and proactive approach that I believe drives the best results for compliance leaders. This blog series aims to address some of the most common but least addressed hurdles that compliance professionals strive to overcome. Sign up for our newsletter to ensure you are up to date on the latest commando blog posts!