Donna Boehme – Corporate Compliance Insights – February 13, 2015
Riddle me this; you are a C-Suite adult at the world’s second largest banking conglomerate, with at least 1.9 billion reasons to establish a compliance program. Do you (a) hire the best, experienced chief compliance officer with a successful track record that your well-paid headhunter army can find and position them for success with the right mandate and resources,or (b) acquire with fanfare an ex-British spy (former head of MI-5) and an ex-U.S. DEA agent to impress your regulators and PR Wizards of Smart? Here is my not surprised face at HSBC’s election of (b) => :/ zzz. Because that worked out so well for Barclay’s, right?
Well, how about Option (c)? Maybe Harrison Ford can be persuaded to come on board and do a little “DIY Compliance”(because at least some of his past movie plot lines involved international money-laundering!!) And then everyone can join hands and sing Kumbaya! Dear Boards and C-Suites: Please be advised that ‘big name’ ex-regulators and law firm partners are no more likely to deliver a meaningful ethics and compliance program to your companies than Harrison Ford as Indiana Jones or Jack Ryan! It is maddening to watch companies in compliance trouble keep making Rookie Mistake #2: the fatally misguided belief that a high profile candidate with a legal regulatory, law firm or prosecutorial background is the silver bullet for those problems! And shame on the regulators and prosecutors who fall for that fairytale!