Where to Begin

First rule:

Make sure Management is aligned with your objectives.  “Tone at the top” is a key factor in your success.  Every compliance person I know has experienced Management that is only partially “on board”.  When you meet with them, they sound aligned with your plan but they later sabotage (purposely or inadvertently) your efforts with lack of resources, failure to drive accountability, or rapidly changing priorities.  You cannot create an effective, sustainable compliance program without some support at the Management level.  I say “some” support because you also need to be realistic about their enthusiasm.  If they will provide the resources and hold the organization accountable for the plan, you’re way ahead in the game.  They will most likely never embrace compliance with a passion that equals your own.  Don’t lose sleep over it.

Your job is to communicate the needs clearly, keep them engaged and to continue to reinforce the need for support of your planned actions.  Let’s be honest, compliance is not a sexy topic.  It is not usually a revenue generator and even the best-intentioned attempt to detail the benefits of  “cost avoidance” prompts guaranteed yawns and BlackBerry checking.  Fear works well to get the attention of Management initially but be careful not to overplay the jokes about how nice the President will look in stripes. 

Someone in management, for some reason, has decided that a compliance program is needed.  The reason is most likely linked to competitiveness and a strategic plan.  In other words, your purpose has already been established, no need to sell it further.  Your job is to deliver the outcomes that will support the business objectives.  Your best approach is to create and communicate well-stated, achievable, measurable goals.  Understand the scope of the project and the impact to available resources.  Employ sound project management techniques to ensure effective communications, well controlled plan changes and to avoid scope creep.  Identify the risk factors and key assumptions up front so that you have contingency measures in place.

Most importantly, don’t try to boil the ocean.  As the subject matter expert, you should have a solid grasp of what is critical and what can be delayed for future action.   After all, there is a reason it’s called continuous improvement.  Your efforts to achieve compliance “nirvana” will be ongoing well into the future.