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A Compliance ROI is the foundational component of Compliance as a Competitive Advantage, and like any new initiative, it requires a shift in perspective and focus. It requires a shift in emphasis away from one-day-at-a-time responsiveness towards building sustainable processes that also contribute to the business bottom-line. Federal authorities already recognize this value. The U.S. Department of Justice (“DoJ”) routinely instructs federal and state prosecutors to gauge the proactiveness and sustainability of a given firm’s compliance program when a violation is detected or reported. As the recently updated DoJ Guidance on Corporate Compliance Programs makes clear, the more sustainably a business is governed, the less likely it will be required to spend on fines and remediation.* Compliance programs can effectively demonstrate their ROI by mitigating such risks.

An organization’s routine compliance functions such as training, testing and the quarterly/annual reporting can serve as prime opportunities for evidencing a Compliance ROI.

But as the DoJ’s evaluation reminds us, this assessment should be ongoing so your compliance program is not static. Compliance issues, such as a cyberattack, can arise quickly. Internalizing Triple-Bottom Line Compliance means stretching any response above and beyond what is expected with a protection-only approach and applying new visions to find business benefits and operational efficiencies as well. That vision should be spearheaded by you, but fortified by experts and allies both within and without your organization. ROI is not only a proactive initiative, but a shared one as well.

*Further information on the DoJ guidelines can be found here.

Also consult Episode 10 of Warburton’s What’s Ethical podcast, where Craig Salm of Grayscale Investments gives valuable advice on how he delivers a ROI advising on digital assets.

Beth Haddock is the author of Triple Bottom-Line Compliance – How to Deliver Protection, Productivity and Impact. She advocates delivering sustainable compliance that increases brand protection, risk mitigation, productivity, and employee engagement.

“A foolish consistency is the hobgoblin of little minds,” Ralph Waldo Emerson

Q: In your opinion, what are the most important skills a new CCO or compliance officer should master?

A: Above all, compliance officers are well-served if they remember that the control environment should be aligned with the business environment and both should develop as they learn from mistakes and successes.

As Ralph Waldo Emerson once warned, “A foolish consistency is the hobgoblin of little minds.”

There are three ways compliance officers can develop skills so that controls don’t remain static and contribute to repeated deficiencies, patterned behavior of apathy or a misconception that compliance is bureaucratic.

1. Avoid Predictable Surprises: Compliance officers safeguard not only their businesses but themselves against falling prey to Predictable Surprises. Referred to by Harvard Business Review as “the disasters you should have seen coming,” these surprises can only be effectively met by rooting out our own cognitive flaws that enable them and not agreeing to let known gaps persist. Your organizational controls should be revisited at least annually for relevance and effectiveness. Within the Circle of Compliance cycle, changes to the business and regulatory environment are constant and must be accounted for in procedures and risk assessments. And if you don’t have time, be certain to ask for help before your company falls behind.

2. Prioritize Risks: Compliance officers should know how to effectively position compliance risks within current industry developments. The recent OCIE Risk Alert on Regulation S-P Privacy Notice and Safeguard violations can illuminate improvements your business can implement. If it doesn’t, compliance officers only need to point to the estimated $5 billion fine Facebook must pay the FTC as a sobering example of consequence.

3. Track Industry Trends: No resource is more valuable to a compliance officer than up-to-date information. Be sure to attend conferences, roundtables and maintain networking. Fresh perspectives on one’s profession can prevent one’s own from becoming stale.

Beth Haddock is author of Triple Bottom-Line Compliance – How to Deliver Protection, Productivity and Impact, and advocates delivering sustainable compliance that increases brand protection, risk mitigation, productivity, and employee engagement.