Compliance Culture Enhancement

Compliance culture: Built in, not bolted on—and it starts at the top Because “We’ll fix it later” is not a strategy Let’s get something straight: 👉 #Compliance isn’t Legal’s job. It’s everyone’s job. And it starts with the CEO. If you treat compliance like the department that ruins good ideas, you’ll build a team that hides problems, skips guardrails, and prays no one notices. If you treat compliance like a growth enabler—like the quiet power behind trust, scale, and survival— You’ll build a culture that wins in the long game. And make no mistake: that mindset starts at the top. 🧠 What I’ve learned leading regulated companies I’ve led startups in digital assets, capital markets, wealth management—you name it. All regulated. All fast-moving. And here’s what I’ve learned: 👉 You can’t bolt on compliance. You have to build it in. From day one. Not Series B. Not when a regulator shows up. From the first product sprint, the first client onboarded, the first jurisdiction explored. According to a 2023 McKinsey report, startups that embed compliance early are 3x more likely to achieve regulatory approval in new markets without delays—and raise more capital with fewer legal caveats. 🛠️ How you build a compliance-first culture You don’t need to turn your company into a law firm. You need to build muscle memory. Here’s what I do at every company I lead: 1. Normalize escalation. If it smells weird, flag it. We don’t punish red flags—we reward them. 2. Involve compliance early. Not at the end of a build. They sit at the table from Day 0. 3. Treat regulators like stakeholders. You don’t hide from them—you build with them. 4. Celebrate risk ownership. When someone raises their hand and says “We can’t launch this yet”—that’s leadership. 5. Keep a regulatory log. Not sexy. But powerful. Consistency and clarity beat charisma when the regulator calls. 💡 It’s a culture problem, not a compliance problem If your team sees compliance as the department of “no,” that’s on you. Because the best cultures don’t just comply with the rules—they own them. They understand that compliance isn’t what slows you down— It’s what keeps you from getting shut down. As CEO, your job isn’t just to ship product, raise capital, or win deals. 🥊 Your job is to build a company that can survive its own growth. That means embedding compliance in your culture like it's oxygen— Silent, ever-present, and essential. You don’t just lead compliance with policies. You lead it with posture. And that posture starts with you. #CEO #Compliance #FinTech #Regulation #RiskManagement #Leadership #Trust #FinancialTechnology #Regulations #CEOs #Management

Audit Red Flags: Lessons from the Frontline I asked several external auditors across the EU to share the most alarming feedback they’ve encountered during inspections over the past five years. Their answers were both revealing and unsettling, highlighting systemic issues that demand attention from leadership. Here are some of the most striking examples: • “I escalated and was told to continue as it is.” This suggests a culture where raising concerns is not just discouraged but actively ignored, allowing non-compliant practices to persist unchecked. • “I know, but when I report, nothing has been done; it’s been this way for years.” This reflects a systemic neglect of compliance risks, leading to a breakdown of trust in the organization’s ability to address critical issues. • “It’s not my responsibility.” A lack of ownership creates dangerous gaps in processes and controls, increasing the likelihood of compliance failures. • “We prioritize operational output over compliance.” When compliance is sidelined for productivity, organizations may risk of-becoming a culture of corner-cutting. • “We don’t have the resources to address that.” Resource constraints can leave critical gaps in compliance frameworks • “I wasn’t aware that was required.” Training and communication failures mean employees may unintentionally breach regulations • “We’ve always done it this way; why change now?” Resistance to change or adherence to outdated practices stifles progress and can result in non-compliance with evolving regulations. These responses reflect systemic failings in governance, accountability, and cultural alignment. Addressing these issues requires a holistic approach: 1. Cultural Transformation Leadership must foster an environment where employees feel empowered to report concerns without fear of retaliation. Building a compliance-first culture means embedding ethical behavior into the DNA of the organization. 2. #Accountability at All Levels #Compliance should not be seen as the responsibility of a single department. Clear roles and responsibilities must be defined, ensuring everyone understands their part in maintaining regulatory adherence. 3. Resource Allocation Compliance cannot be an afterthought. Organizations must invest in the right tools, personnel to ensure systems are robust and scalable. 4. Ongoing Training and Communication Regulations evolve, and so must your workforce’s understand them. Regular training sessions ensure employees remain informed and capable. 5. Proactive #RiskManagement Waiting for an inspection to identify issues is reactive and costly. Organizations should conduct regular internal audits to identify and address compliance gaps before they escalate. 6. Leverage Technology Technology can streamline compliance monitoring, reduce human error, and improve reporting capabilities. From automated risk assessments to AI-driven analytics, the tools are out there—invest in them. #CorporateGovernance #OperationalExcellence

This weekend, I was preparing a gap analysis of a Compliance program.   After having experience implementing COMPLIANCE across various sectors – from state-owned enterprises and municipal and regional-owned companies to private sector organizations – I came to a clear conclusion about what is essential for an EFFECTIVE compliance program:   1. COMPETENCE ↳ An effective compliance program starts with competencies. Where does compliance risk arise? Wherever people work. To minimize that risk, we must provide employees with the knowledge and skills necessary to responsibly perform their tasks.   2. POLICY AND PROCEDURE ↳ Policies and procedures must be clearly defined. They should not only meet regulatory requirements but also help employees understand why certain behaviors are important.   3. ROLES AND RESPONSIBILITIES ↳ Every individual must clearly understand their responsibilities within the compliance framework. Clarity reduces the risk of errors and strengthens personal accountability.   4. SPEAK UP ↳ A culture where employees feel free to report irregularities or suggest improvements is crucial for strengthening the compliance program. It is easy to write this down but very challenging to achieve in practice.   5. COMMUNICATIONS ↳ Open, clear, and two-way communication about rules, expectations, and opportunities is key for effective compliance implementation.   6. CONTINUAL IMPROVEMENT ↳ Compliance is not static. The program must continually adapt to changes in the business environment and proactively prevent future irregularities.   7. BALANCE OF RISK AND GOALS ↳ To foster truly responsible behavior, organizations must balance ambitious targets with acceptable levels of risk. Excessive pressure, unrealistic expectations, and constant high stress not only undermine compliance efforts, but they also actively create an environment where mistakes, omissions, and misconduct become more likely. And most importantly...   8. LEADERSHIP COMMITMENT ↳ When leadership actively lives and integrates all these elements – competence development, purposeful procedures, clear roles, open communication, a speak-up culture, continuous improvement, and balance of risk and goals, they demonstrate true commitment to compliance.   📌 Compliance must be a living system of values, and employees should feel it as part of their professional purpose, not as an imposed rule.   Wishing you a successful start to Compliance Week! 👋 #compliance

How does a company go from facing $218 million in FCPA violations to being named Compliance Program of the Year? I recently had the opportunity to write an article for the Society of Corporate Compliance and Ethics (SCCE) and discuss the Albemarle case. When I sat down with Andrew McBride, Albemarle’s former chief risk and compliance officer, I didn’t know I was about to uncover one of the most transformative compliance journeys I’ve seen in my career. How did they get there? What did they change? And, more importantly, what can the rest of us learn? From my conversation with Andrew, here’s what stood out: ⏰ Start early: Albemarle’s proactive remediation efforts helped minimize fines and rebuild trust before the dust even settled. 🧬 Embed compliance everywhere: Through corporate training programs and daily operations, ethics became part of the company’s DNA.   📊 Leverage the data: Real-time analytics provided the transparency and control needed to create a culture of accountability. What struck me most was Albemarle’s commitment to cross-functional collaboration. Albemarle was relentless in completely reshaping perceptions and integrating compliance into every corner of the business. This case stands out as a testament to the power of leadership, transparency, and trust. It’s proof that even the most complex situations can be the catalyst for lasting improvement. Want to know more about how Albemarle turned a crisis into a benchmark of excellence? Check out the full story here: https://lnkd.in/g5xkX7i4

Compliance isn’t a checklist. It’s a culture. And if you want fewer citations, stronger audits, and safer patients? You need to build that culture on purpose. Because when the surveyor walks in unannounced… When your infection logs don’t match the floor reality… When frontline staff freeze instead of acting… It’s already too late. Policies won’t protect you. Intentions won’t matter. And no one gets a do-over. Here’s the truth: Most facilities don’t fail surveys because they don’t know what to do. They fail because they don’t practice it daily. Compliance isn’t about having protocols. It’s about reinforcing habits when no one’s watching. Hand hygiene logs. Micro-trainings. Shadowing rounds. Behavior-driven audits. It’s not complicated. But it is consistent. If you’re ready to lead a culture that passes surveys before they even happen... 👇 Here’s a cheatsheet of 15 infection control habits that stick. Use it. Or keep hoping policies will do what culture never could.

Applying The Art Of Kintsugi To Compliance Programs What happens in your organization when someone has done something that is inconsistent with your compliance program standards? Is the matter quietly dealt with to try to put things back together as seamlessly as possible and so that no one (other than those who already know or have a need to know) will know an issue ever existed? Kintsugi is a Japanese form of art where broken pottery and other ceramics are repaired using a gold-dusted lacquer to put the broken pieces back together. Instead of hiding the damage and trying to make it look like the original, kintsugi visibly highlights the repair work and the gold coloring often makes the pottery even more impressive looking than before. The art form is not about naming and shaming who broke the ceramic in the first place, but about acknowledging that something happened and embracing the damage done to put the broken pieces back together. People make mistakes - they will not do what is expected of them at times, and they will also break ceramics. While we aim to reduce the likelihood of both, we are always going to have to deal with situations in which damage has been done. Rather than hide when people have made mistakes or violated your compliance program standards, you can use those examples (and you do not have to name and shame) to help rebuild any broken parts of your program, make it stronger and embrace what happened to help others. Use stories from within your organization to share with others what happened and what was done. Talk about the root causes and contributing factors that lead to the issue. Help employees understand that your organization’s compliance (and other) standards matter and that you look to build a culture where people learn from mistakes. Trying to hide past compliance issues is a mistake - acknowledge what happened because transparency helps build trust, it shows that the program is driven by continuous improvement, and demonstrates that the organization looks to strengthen itself based on the past. #SundayMorningComplianceTip #EthicsAndComplianceForHumans 📚 Want to get more compliance ideas and tips like this? Connect with me here on LinkedIn, get your copy of my book called Ethics & Compliance For Humans (published by CCI Press), and subscribe to our newsletter called Compliance and Ethics: Ideas & Answers.

"If You Think Compliance Is Expensive, Try Non-Compliance." Former US Deputy Attorney General Paul McNulty's powerful insight. Compliance is not just about avoiding penalties. → Understand the true costs of non-compliance. Review the key impacts: • Regulatory fines • Revenue loss • Reputational damage • Halted operations • Legal ramifications → Invest in proactive compliance systems. Use the best tools: • Real-time monitoring • Automated reporting • Risk assessment • Cross-functional compliance team • Regular audits → Make compliance a core value, not just a policy. Create a culture of integrity: • Ethical responsibility • Ownership of actions • Leadership championing compliance • Embedded in team meetings • Company-wide addresses → Foster accountability and ownership at every level. Empower your team: • Clear compliance goals • Personal accountability • Encourage reporting without fear • Rewards for ethical behavior → Share success stories and lessons learned. Highlight real-world examples: • Consequences of non-compliance • Internal successes • Cost savings • Improved processes • Avoided risks → Continuous improvement and training. Stay updated: • Regular training • Latest tools and practices • Review and update strategies • Align with current standards Compliance is a path to sustainable success. Embrace a legacy of excellence and responsibility.

5 Ways to be a Hands-On Chief Compliance Officer (CCO) Take these steps to lead from the front: “Success in compliance is knowing the rule and how to apply it.” The Power of a Hands-On Approach: • Staying proactive • Embracing practical experience • Building genuine relationships across the board • Mere #Leadership lectures won't work. Step 1: Read, Read & Know Absorb, and understand everything from regulatory changes to company culture nuances. Ask yourself: • What's the latest regulatory update? • How might it impact my team? • How can I simplify these updates for stakeholders? Reading widely sharpens your radar for potential risks and Builds a rich repository of knowledge you can draw on instinctively. Step 2: Get the Hands Dirty Go beyond analysis and theory—dig into real cases, processes, and day-to-day operations. Consider: • Are there workflows you can directly experience or streamline? • Can you sit in on calls to see how compliance challenges are managed on the ground? • Work with Subject experts not just generalists. Being hands-on allows you to see issues and improvements up close. It’s not just a desk job get involved! Step 3: Work with Peers Build strong alliances across departments. Other teams can be invaluable compliance allies. Ask yourself: • How often do I meet with other departments? • Are we aligned on key compliance priorities? • What do they need to know from me to stay compliant? • Meet CRO, IA Head, GC Collaboration with peers strengthens compliance at every level, making it a collective effort rather than a solo mission. Step 4: Understand Regulators Knowing what regulators value and expect is crucial for risk-proofing. Reflect: • What are the current priorities of our primary regulators? • What trends are we seeing in regulatory focus? • How can I anticipate their concerns before they’re raised? Being proactive with regulators can make a significant difference in both compliance and reputation. Step 5: Hear the Business Voice Compliance is about partnership, not policing. Align with business objectives to become a trusted advisor. Consider: • Am I aware of key business strategies and timelines? • Do I know the risks business leaders worry about most? • How can I frame compliance goals to support their objectives? By balancing compliance with business goals, you gain respect and Ensure compliance is embedded naturally. 🔗 Explore more resources: https://lnkd.in/gh_EYapE Follow Abhishek R. Sharma. I help BFSI mid-career professionals to “upskill” and “achieve career growth” in the “compliance domain”, using my patented PERKS Model. 👉 Follow The Upskill School on LinkedIn for exclusive insights:  👉 Subscribe on YouTube for more videos: https://lnkd.in/ewN8NAdK 👉 Repost this for the benefit of your community.

The DOJ's 2024 update to the ECCP reshapes the compliance landscape by emphasizing data-driven insights and a strong compliance culture. This new focus requires organizations to move beyond implementing policies and demonstrate their impact through measurable outcomes. Compliance professionals now face the challenge of tracking culture, engagement, and trust metrics to meet these standards. From conducting regular culture audits to integrating compliance with incentives, the ECCP highlights how data and transparency can turn compliance into a strategic advantage. Dive into the key areas and learn how to stay ahead: https://bit.ly/4ee7OY7. #Compliance #ECCP2024 #CorporateCompliance #DataDrivenCompliance #CultureOfCompliance

Compliance isn’t the problem. Leadership buy-in is. I’ve seen this play out more times than I can count: 👉 Compliance is looped in after the decisions are made 👉 They’re labeled “difficult” for asking the right questions 👉 Leadership assumes that hiring someone with the title is enough Here’s the truth: You can’t delegate ownership and expect accountability. Compliance only works when it’s supported from the top. That means budgets, timelines, influence-and most of all, trust. If your compliance team is constantly playing catch-up, or if you’re burning through people who “just weren’t a good fit,” maybe it’s time to ask: Was it them? Or was it the environment we handed them? 💡 Real compliance culture doesn’t start with hiring someone. It starts with backing them. #ComplianceCulture #Leadership #ProductSafety #Accountability #RiskManagement #CPSC #TrustTheProcess