Compliance and Ethics: Ideas & Answers. Edition 131

Dear friends,

Welcome to the 131st edition of Compliance and Ethics: Ideas & Answers.

This week, Adam Balfour explores how data analytics can strengthen compliance programs, when used wisely. From avoiding hasty conclusions based on a single data point to balancing quantitative and qualitative insights, his piece shows us how to turn raw numbers into meaningful actions that actually improve our programs.

Meanwhile, Paul McGreal launches a new three-part series on preparing law students for careers in compliance. In this first installment, he offers practical advice for those considering the path, from cultivating a compliance mindset to learning the language of business, skills that can transform lawyers into proactive partners in organizational integrity.

And in Compliance Lite, Karen M. Leet lightens the mood with “Laughter,” a personal reflection on humor, storytelling, and what happens when a compliance professional can’t tell a joke, so she enlists her sassy Irish Grammy instead.

Here’s a suggestion: if something in this issue resonates, share it with someone in your network — it might be exactly what they needed to read.

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Thank you,

The Editors

What Does Your Ethics & Compliance Program Data Tell You?

by Adam Balfour

Data analytics can provide valuable insights for compliance programs, including measuring program effectiveness and helping us make better decisions. To get the value from data analytics, we have to make sure we don’t get lost in the data and that we are intentional about what data we analyze and what conclusions we draw. Here are some points to keep in mind when it comes to data analytics:

1. A Single Point Is Not a Conclusion: This is something that my fellow Ideas & Answers editor, Joe Murphy, CCEP, appropriately cautions in our conversations - be careful not to make sweeping judgments or conclusions based on one data point. This is especially the case when the lone data point supports our pre-existing views - avoid the temptation to form conclusions based on limited data, and make sure you have enough data before forming conclusions.

2. Look Beyond The Averages: Aggregated data can be useful, but it can also hide part of the story. For example, company wide training completion rates might look high, but could be masking a specific business unit with a very low completion rate. The key is to find the balance between what the aggregated data indicates and looking for the significant outliers that might otherwise be missed.

3. What Type Of Data Do You Have?: Having quantitative data (such as the number of helpline reports for a particular location) might be useful and indicate what is happening, but you might not have the complete picture without qualitative data showing why (including data from employee surveys or interviews). Will only looking at one type of data give you the complete picture?

4. What Do You Do With The Data?: Having data is not enough - you need to know what to do with the data. Does the data answer questions or provide conclusions? Does it help you ask better questions and help you look for additional data? Who needs to know about the data and the possible insights? Data analytics is more than just collecting data - you need to know what insights you can form based on the data and what actions to take next.

Data analytics can be incredibly valuable when approached in the right way. The value comes not just from having data, but pairing the data with experienced insights and followed by action.

Part 1: So You Want to Be a Compliance Professional? Advice for Law Students

by Paul McGreal

Picture this: A Fortune 500 company discovers that its star salesperson has been making “facilitation payments” to foreign officials for years. Upon a closer look, these payments turn out to be illegal bribes under U.S. law. The company’s General Counsel turns to the Chief Compliance and Ethics Officer and asks, “How did we miss this?” This scenario illustrates why the legal profession needs more lawyers who understand not just how to respond to problems, but how to prevent them.

Yet legal education has a blind spot when it comes to preparing students for careers in compliance. While law schools have many courses on litigation and transactional practice, few schools offer exposure to the preventive discipline of compliance. This gap leaves most students unaware of a career path that combines legal expertise, business skills, and ethical leadership.

This article—the first in a three-part series—starts to bridge that gap by providing guidance to law students interested in compliance careers. The next article will examine how law schools can better promote and prepare students for careers in compliance. And the last installment will explore how the compliance profession can help promote the field to law students and recent law school graduates. But first, I will address the law student wondering whether compliance might be their calling.

Understand the Compliance Mindset

A good place to start is this: compliance professionals work diligently to cultivate an organization that empowers and motivates people to do the right thing. Your litigation-focused classmates are training to be legal firefighters, rushing in after a fire has started. Compliance professionals are the architects who design a safer building, and this proactive mindset shapes how they approach their work. They think in terms of systems, controls, and organizational culture that reduce legal and ethical risks so that an organization is more effective at serving its mission. When you internalize this perspective, you’ll find yourself asking different questions: not “how do we defend this action?” but “how do we design processes that make us better at what we do?”

Prepare to Be Part of the Business team

Compliance professionals do not operate in isolation—they navigate complex corporate environments daily. You will need to understand how boards of directors function, how executives make decisions, and how different departments interact (and sometimes clash). To be effective, you will need to influence decision-making across multiple organizational levels. In some companies, the general counsel might be your supervisor, but you’ll need to work effectively with everyone from the board’s audit committee to human resources to front-line sales managers. Your ability to read these dynamics and work within them separates effective compliance officers from those who write policies that gather dust on shelves.

So, to add value to the organization, knowing the law isn’t enough. If you can’t speak the language of business, you’ll struggle to influence decision-makers. You must understand how the organization makes money. Learn what metrics drive executive compensation. Master the ability to frame compliance objectives in terms that resonate with business leaders. When you can demonstrate how strong compliance drives sustainable profitability—rather than simply imposing costs—you’ll find doors opening that would otherwise remain closed. The most successful compliance officers are those who position themselves as business partners, not police officers.

Continue reading on our website...

Laughter

by Karen M. Leet

What my Grammy from the “Old Country” – which for us is Ireland – always says is this, “laughter is the best medicine.”

I believed it then. And I still believe it now. My Grammy is a wise woman. Sassy, too. Mom always says Grammy is full of vinegar, whatever that means.

Anyway, about laughter. I agree with my sassy old Grammy. Laughter is good. Sometimes it’s great. Sometimes it can hit the ball right out of the park. I mean, I’ve seen it happen at least a hundred thousand times.

Only problem is this – I can’t do it.

Humor, I mean. I have never – and I mean never – been able to tell a joke. Never.

I forget the punchline. Or I tell it backwards. Or I drop my cue cards, and I can’t do it at all.

Here’s the thing. I’m a compliance professional. And I’m good. I mean really good. I care deeply about my job. It’s more than a job to me.

It’s like a calling. What I do matters. It matters to a lot of people, starting with me. It matters to our clients, our business associates, our board of directors and every single one of us working here.

And I’ve been advancing here. People are noticing me, noticing how hard I work, how much I care, how I stay in touch with every update, every change, every improvement in my field.

Compliance matters. To everyone. Whoever it is. Whatever they do. Wherever they go.

Compliance is a growing, developing, expanding field. It’s always changing – just the way life is always changing.

You can’t stand silent in the compliance field. You have to keep up with changes, improvements, nuances.

Life changes. Rules shift. Laws get deeper and stronger. Compliance has to keep up – stay on top of everything – be ready to change constantly.

That’s what I’m good at. I know the field. I watch for shifts and changes. I keep in touch. I see those changes as soon as they start.

Well, management sees me. The board knows my name. Leadership checks in with me.

I am in demand. The higher-ups seek me out, ask my advice, listen to what I tell them.

But that means the bosses ask me to do training sessions. Or speaking engagements. Or updating days.

Know what everyone tells me, though?

Can you guess?

Everyone tells me I need to loosen up first. Start with a few good jokes. Make everyone relax, laugh, be more open, more receptive.

But I can’t tell a good joke. I can’t even tell a bad joke. I’ve never made a crowd laugh.

I can’t even make Grammy laugh. Ever. I am just no good at jokes or funny stories or amusing anecdotes.

So, what do I do now? I’m in constant demand for speaking or training sessions or short update programs. And everyone – I mean everyone – says I need to learn to open up with humor to make everyone at ease, more relaxed, more receptive, more open to what I’ve got to tell them.

What to do, what to do?

Can you guess my new idea? Huh? Can you? Go ahead, guess. Go on. Do it.

Here you go. Ready?

I show my audience a video recording of Grammy telling her best (and cleanest) funny stories.

Everyone laughs. Everyone loosens up. Everyone then settles nicely to hear what I have to say.

Plus, it gives Grammy new career options. Next Tuesday she starts the rounds of internet podcasts – way to go, Grammy!

© 2024 K. Leet

What do you think?

Is laughter important, helpful, fun?

What part does laughter play in compliance?

Can you tell a good (clean) joke?

These are stories (usually fictional, but not always), based on insights and experiences from the world of compliance & ethics. To explore more stories and reflections from the world of compliance & ethics, visit our website.

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