Am I a Good Compliance Officer?

I was recently asked to write an article on what it takes to be a “good” compliance officer.  The question felt enormous.  Should I write about the areas of law a compliance officer is expected to know about?  Should I write about the backgrounds and expertise the compliance officer typically comes from, or qualities that they should possess in order to be effective?  And ultimately, was I a “good” enough compliance officer to even have an opinion about such a subjective idea? It was daunting.
I started with the list of things I look for when I hire new compliance officers.  These include:

  • Strong internal fortitude
  • Capacity to tell the truth
  • Great listening skills
  • Genuine enthusiasm for the topic of compliance
  • Belief in the mission of compliance and ethics
  • Natural curiosity about the law and an interest in it
  • Desire and capacity to create systems and policies that work
  • Capacity for influence, persuasion and communication

As I wrote the piece (which can be viewed here) I began to wonder, how would someone know if they were a “good” compliance officer? Assuming a person has all of the qualities listed above, how would they know if they were effective at the job? 
I thought for a long time about a single criterion which could determine whether a person was good or bad at the job. I finally decided that the best way to determine whether a person is a good compliance officer is whether, over time, the business proactively comes to the compliance officer with problems or to ask for advice.  The most successful compliance officers are those who gain the trust of the business and who become integral to its operations. 
Luckily for all of us there isn’t a single good/bad barometer, and we can always learn, grow and become more effective.  It can be helpful to ask yourself the question: does the business (or important members of it) come to you to seek your advice, ask for your blessing before the projects start, or tell you what is really going on?  Then congratulations – you’re good!  If you’re finding it hard to answer the question in the affirmative- take heart!  We are all learning how to do the job more effectively.  And that, by itself, means we’re “good” and getting better.