Compliance Officer Quotes

While complying can be an effective strategy for physical survival, it's a lousy one for personal fulfillment. Living a satisfying life requires more than simply meeting the demands of those in control. Yet in our offices and our classrooms we have way too much compliance and way too little engagement. The former might get you through the day, but only the latter will get you through the night.

Living a satisfying life requires more than simply meeting the demands of those in control. Yet in our offices and our classrooms we have way too much compliance and way too little engagement. The former might get you through the day, but the latter will get you through the night.

This is Captain Uhtavio Scorandum of the Ethics and Compliance Office ship We Don’t Want to Brag About That Thing You Can’t Prove We Did.

American regulators tend to set up elaborate monitoring regimes, but then are unable to (or fail to) impose meaningful fines for clear wrongdoing. Such regulation appears to be little more than a full employment program for compliance officers and attorneys.

Left-wing progressivism” and “managerialism” are synonymous since the solutions of the former always involve the expansion of the latter. To stay with the example of LGBT causes, these may seem remote from something as technical as “managerialism” but consider the armies of HR officer, diversity tsars, equality ministers, and so on that are supported today under the banner of “LGBT” and used to police and control enterprises. The “philanthropic” endeavours of the Ford Foundation in this regard laid the infrastructure and groundwork to setup new power centres for managerialism under the guise of this ostensibly unrelated cause. Similar case studies can be found in issues as diverse as racial equality, gender equality, Islamist terrorism, climate change, mental health, and the management of the COVID-19 pandemic. The LOGIC of managerialism is to create invisible “problems” which can, in effect, never truly be solved, but rather can permanently support managerial jobs that force some arbitrary compliance standard such as “unconscious bias training”, “net zero carbon”, the ratio of men and women on executive boards or whatever else.

These guys, they work for five years at the Commission, then they become a compliance manager at a hedge fund.” And, he added, he knew that was true because every time an SEC investigator came up to his office he or she would ask for an employment application.

... schools in many industrialized nations were not, for the most part, designed to produce innovative thinkers or questioners -- their primary purpose was to produce workers. The author Seth Godin writes, "Our grandfathers and great grandfathers built schools to train people to have a lifetime of productive labor as part of the industrialized economy. And it worked." To create good workers, educations systems put a premium on compliancy and rote memorization of basic knowledge -- excellent qualities in an industrial worker. (Or, as the cartoonist and Simpsons creator Matt Groening puts it, "it seems the main rule that traditional schools teach is how to sit in rows quietly, which is perfect training for grown-up work in a dull office or factory, but not so good for education.") And not so good for questioning: To the extent a school is like a factory, students who inquire about "the way things are" could be seen as insubordinate. It raises, at least in my mind, a question that may seem extreme: If schools were build on a factory model, were they actually designed to squelch questions?

Sheepwalking I define “sheepwalking” as the outcome of hiring people who have been raised to be obedient and giving them a brain-dead job and enough fear to keep them in line. You’ve probably encountered someone who is sheepwalking. The TSA “screener” who forces a mom to drink from a bottle of breast milk because any other action is not in the manual. A “customer service” rep who will happily reread a company policy six or seven times but never stop to actually consider what the policy means. A marketing executive who buys millions of dollars’ worth of TV time even though she knows it’s not working—she does it because her boss told her to. It’s ironic but not surprising that in our age of increased reliance on new ideas, rapid change, and innovation, sheepwalking is actually on the rise. That’s because we can no longer rely on machines to do the brain-dead stuff. We’ve mechanized what we could mechanize. What’s left is to cost-reduce the manual labor that must be done by a human. So we write manuals and race to the bottom in our search for the cheapest possible labor. And it’s not surprising that when we go to hire that labor, we search for people who have already been trained to be sheepish. Training a student to be sheepish is a lot easier than the alternative. Teaching to the test, ensuring compliant behavior, and using fear as a motivator are the easiest and fastest ways to get a kid through school. So why does it surprise us that we graduate so many sheep? And graduate school? Since the stakes are higher (opportunity cost, tuition, and the job market), students fall back on what they’ve been taught. To be sheep. Well-educated, of course, but compliant nonetheless. And many organizations go out of their way to hire people that color inside the lines, that demonstrate consistency and compliance. And then they give these people jobs where they are managed via fear. Which leads to sheepwalking. (“I might get fired!”) The fault doesn’t lie with the employee, at least not at first. And of course, the pain is often shouldered by both the employee and the customer. Is it less efficient to pursue the alternative? What happens when you build an organization like W. L. Gore and Associates (makers of Gore-Tex) or the Acumen Fund? At first, it seems crazy. There’s too much overhead, there are too many cats to herd, there is too little predictability, and there is way too much noise. Then, over and over, we see something happen. When you hire amazing people and give them freedom, they do amazing stuff. And the sheepwalkers and their bosses just watch and shake their heads, certain that this is just an exception, and that it is way too risky for their industry or their customer base. I was at a Google conference last month, and I spent some time in a room filled with (pretty newly minted) Google sales reps. I talked to a few of them for a while about the state of the industry. And it broke my heart to discover that they were sheepwalking. Just like the receptionist at a company I visited a week later. She acknowledged that the front office is very slow, and that she just sits there, reading romance novels and waiting. And she’s been doing it for two years. Just like the MBA student I met yesterday who is taking a job at a major packaged-goods company…because they offered her a great salary and promised her a well-known brand. She’s going to stay “for just ten years, then have a baby and leave and start my own gig.…” She’ll get really good at running coupons in the Sunday paper, but not particularly good at solving new problems. What a waste. Step one is to give the problem a name. Done. Step two is for anyone who sees themselves in this mirror to realize that you can always stop. You can always claim the career you deserve merely by refusing to walk down the same path as everyone else just because everyone else is already doing it.

When trying to understand why people acted in a certain way, you might use a short checklist to guide your probing: their knowledge, beliefs and experience, motivation and competing priorities, and their constraints. •​Knowledge. Did the person know something, some fact, that others didn’t? Or was the person missing some knowledge you would take for granted? Devorah was puzzled by the elderly gentleman’s resistance until she discovered that he didn’t know how many books could be stored on an e-book reader. Mitchell knew that his client wasn’t attuned to narcissistic personality disorders and was therefore at a loss to explain her cousin’s actions. Walter Reed’s colleagues relied on the information that mosquitoes needed a two- to three-week incubation period before they could infect people with yellow fever. •​Beliefs and experience. Can you explain the behavior in terms of the person’s beliefs or perceptual skills or the patterns the person used, or judgments of typicality? These are kinds of tacit knowledge—knowledge that hasn’t been reduced to instructions or facts. Mike Riley relied on the patterns he’d seen and his sense of the typical first appearance of a radar blip, so he noticed the anomalous blip that first appeared far off the coastline. Harry Markopolos looked at the trends of Bernie Madoff’s trades and knew they were highly atypical. •​Motivation and competing priorities. Cheryl Cain used our greed for chocolate kisses to get us to fill in our time cards. Dennis wanted the page job more than he needed to prove he was right. My Procter & Gamble sponsors weren’t aware of the way the homemakers juggled the needs for saving money with their concern for keeping their clothes clean and their families happy. •​Constraints. Daniel Boone knew how to ambush the kidnappers because he knew where they would have to cross the river. He knew the constraints they were operating under. Ginger expected the compliance officer to release her from the noncompete clause she’d signed because his company would never release a client list to an outsider.

Type II trauma also often occurs within a closed context - such as a family, a religious group, a workplace, a chain of command, or a battle group - usually perpetrated by someone related or known to the victim. As such, it often involves fundamental betrayal of the relationship between the victim and the perpetrator and within the community (Freyd, 1994). It may also involve the betrayal of a particular role and the responsibility associated with the relationship (i.e., parent-child, family member-child, therapist-client, teacher-student, clergy-child/adult congregant, supervisor-employee, military officer-enlisted man or woman). Relational dynamics of this sort have the effect of further complicating the victim's survival adaptations, especially when a superficially caring, loving or seductive relationship is cultivated with the victim (e.g., by an adult mentor such as a priest, coach, or teacher; by an adult who offers a child special favors for compliance; by a superior who acts as a protector or who can offer special favors and career advancement). In a process labelled "selection and grooming", potential abusers seek out as potential victims those who appear insecure, are needy and without resources, and are isolated from others or are obviously neglected by caregivers or those who are in crisis or distress for which they are seeking assistance. This status is then used against the victim to seduce, coerce, and exploit. Such a scenario can lead to trauma bonding between victim and perpetrator (i.e., the development of an attachment bond based on the traumatic relationship and the physical and social contact), creating additional distress and confusion for the victim who takes on the responsibility and guilt for what transpired, often with the encouragement or insinuation of the perpetrator(s) to do so.

The successful individual sales producer wins by being as selfish as possible with her time. The more often the salesperson stays away from team members and distractions, puts her phone on Do Not Disturb (DND), closes her door, or chooses to work for a few hours from the local Panera Bread café, the more productive she’ll likely be. In general, top producers in sales tend to exhibit a characteristic I’ve come to describe as being selfishly productive. The seller who best blocks out the rest of the world, who maintains obsessive control of her calendar, who masters focusing solely on her own highest-value revenue-producing activities, who isn’t known for being a “team player,” and who is not interested in playing good corporate citizen or helping everyone around her, is typically a highly effective seller who ends up on top of the sales rankings. Contrary to popular opinion, being selfish is not bad at all. In fact, for an individual contributor salesperson, it is a highly desirable trait and a survival skill, particularly in today’s crazed corporate environment where everyone is looking to put meetings on your calendar and take you away from your primary responsibilities! Now let’s switch gears and look at the sales manager’s role and responsibilities. How well would it work to have a sales manager who kept her office phone on DND and declined almost every incoming call to her mobile phone? Do we want a sales manager who closes her office door, is concerned only about herself, and is for the most part inaccessible? No, of course not. The successful sales manager doesn’t win on her own; she wins through her people by helping them succeed. Think about other key sales management responsibilities: Leading team meetings. Developing talent. Encouraging hearts. Removing obstacles. Coaching others. Challenging data, false assumptions, wrong attitudes, and complacency. Pushing for more. Putting the needs of your team members ahead of your own. Hmmm. Just reading that list again reminds me why it is often so difficult to transition from being a top producer in sales into a sales management role. Aside from the word sales, there is truly almost nothing similar about the positions. And that doesn’t even begin to touch on corporate responsibilities like participating on the executive committee, dealing with human resources compliance issues, expense management, recruiting, and all the other burdens placed on the sales manager. Again,

went to the White House and got the President out of bed. Carey and President Harrison were said to be old Senate friends, and no one was present at this session to speak for Johnson County. Quickly convinced of the necessity for immediate action, Harrison ordered a telegram send to General John R. Brooke in Omaha shortly after 11:00 P.M.4 At 11:05 P.M. the president wired Governor Barber that “in compliance with your call for the aid of the United States forces to protect the state of Wyoming against domestic violence,” he had ordered the secretary of war to send troops.5 The president did not have his facts right — the state of Wyoming needed no saving from domestic violence — but Governor Barber made no effort to set the record straight. At 11:37 P.M. General Brooke telegrammed Governor Barber, informing him that the commanding officer at Fort McKinney had been ordered “to prevent violence and preserve peace.”6 This message was received in Buffalo at 12:05 P.M., and within two hours, troops rode out of Fort McKinney under orders from the post’s commanding officer, Colonel J. J. Van Horn.7

On April 18, 2013, the ACRC held a meeting where the Anti-Corruption & Integrity Policy Guidelines were distributed to compliance officers from 450 public organizations

and 300 compliance officers responsible for the codes of conduct of public organizations. Moreover, in 2014, the Commission is planning to reform the “Operational

In our offices and our classrooms we have way too much compliance and way too little engagement. The former might get you through the day, but only the latter will get you through the night.

The strongest deterrent against corporate crime is the prospect of prison time for individual employees.” – Lanny Breuer

While police insist on the need for firearms, the vast majority of officers never fire their weapons and some brag of long careers without even drawing one on duty. Some will say it acts as a deterrent and bolsters police authority so that other force isn’t necessary. This may be true at the margins, but to rely on the threat of lethal force to obtain compliance flies in the face of “policing by consent.” The fact that police feel the need to constantly bolster their authority with the threat of lethal violence indicates a fundamental crisis in police legitimacy.

Thus far, Trump’s bet has paid off to an astonishing degree. Nobody has taken up his dares. Congress has done little, though it may be beginning to stir. The courts, limited by the slow pace of litigation and legitimate substantive and procedural legal barriers to action, offer little short-term relief. So far, anyway, the only real pushback has come from prosecutors and state attorneys general who have probed the conduct of his campaign and foundation. And it has come from a dogged and relentless press, which has accomplished a great deal of disclosure—disclosure that, in turn, gives rise to the possibility of political response. As other billionaires eye the presidency, it’s not hard to imagine them following the example of minimal ethical compliance and preserving their business entanglements. Contrary to former OGE director Shaub’s admonition, as far as some very rich people were concerned, divestment has, in fact, been too high a price to pay for the presidency. Now, it seems, it doesn’t need to be paid after all. As Trump has set the presidency to protecting his personal business interests and dared the polity to stop him, the polity has responded with a shrug. Perhaps a disgusted shrug, but a shrug nonetheless.

In a bureaucracy, every new challenge spawns a new fiefdom, usually headed by a CxO. Today, it’s not unusual for a company to have a chief compliance officer, chief digital officer, chief diversity officer, chief environmental officer, chief transformation officer, and more. Every freshly minted CxO will set up new committees, issue new policies, and demand the collection of new data. There will be more check-ins and sign-offs, more turf battles, and more cooks in the kitchen. The result: more overhead, less accountability, and ever-longer decision cycles.

Traders today complain of living in fear that chats from a bygone era will be dredged up and used against them. They paint a picture of a world where communications are monitored, compliance officers roam the trading floors and it's hard to make an honest living. Banks have finally got the picture, they claim. Market manipulation on the scale we've seen over the past few years is no longer possible. Time will tell (p. 174).

What was your first day like at your current (or most recent) job? Is it fair to say that it was not a defining moment? You show up. The receptionist didn't think you were starting until next week...Your boss has not arrived yet. You're given an ethics and compliance manual to review. The sexual harassment policy is so long and comprehensive it makes you wonder a bit about your colleagues. Eventually, a friendly person from your floor introduces herself and whisks you around the office, interrupting 11 different people...You immediately forget all their names. Except Lester, who might just be the reason for the sexual harassment policy? Does that sound about right?

the lab’s essential public health functions could be compromised during the move and if the lab had fewer employees. The lab, now at a former Devon Energy Corp. field office building next to a cow pasture in Stillwater, has struggled to keep its top director and other key employees. Delays to get test results for basic public health surveillance for salmonella outbreaks and sexually transmitted infections have shaken the confidence of lab partners and local public health officials. As a new coronavirus emerges going into winter, the lab ranks last in the nation for COVID-19 variant testing. Many employees, who found out about the lab’s move from an October 2020 press conference, didn’t want to relocate to Stillwater. Those who did make the move in the first few months of 2021 found expensive lab equipment in their new workplace but not enough electrical outlets for them. The lab’s internet connection was slower than expected and not part of the ultra-fast fiber network used across town by Oklahoma State University. A fridge containing reagents, among the basic supplies for any lab, had to be thrown out after a power outage. Meanwhile, the Centers for Medicare and Medicaid Services finalized a correction plan after federal inspectors, prompted by an anonymous complaint, showed up unannounced at the lab in late September. “Although some aspects of the original report were not as favorable as we would have liked, the path of correction is clear and more than attainable,” Secretary of Health and Mental Health Kevin Corbett said Tuesday in a statement about the inspection. “We are well on our way to fully implementing our plan. (The Centers For Medicare and Medicaid Services) has confirmed we’ve met the requirements of being in compliance. We are looking forward to their follow-up visit.” In an earlier statement, the health department said the Stillwater lab now “has sufficient power outlets to perform testing with the new equipment, and has fiber connection that exceeds what is necessary to properly run genetic sequencing and other lab functions.” The department denied the lab had to throw out the reagents after a power outage.

TW-17. It can also be used to control an opponent by firmly grasping their head with one arm and driving a knuckle or fingertip into the point for compliance. Force should be applied towards to the tip of the nose for best effect. This type of control technique is commonly taught to Law Enforcement Officers as part of their training in dealing with a passive, but non-compliant, protesters, for instance. Defensively, attacks to the side of the head can generally be effectively blocked using the shoulder, arm, or movement of the torso.

Criminal wealth is reinvested, which makes criminals richer and more potent adversaries, while companies in the City poach law enforcement officers to work in their compliance departments. It’s like expecting the army to fight a war against an adversary that gets stronger all the time, while its service men and women are continually lured away to work as private security contractors or, worse still, as mercenaries for their former adversaries. You don’t have to be a conspiracy theorist to start wondering if there isn’t something going on, because this is a system that is not working at all.

Two minutes after she entered the building, a light appeared in a third-floor window. A rapid check of a government property database indicated that the unit in question was owned by an Isabel Brenner, a citizen of the Federal Republic of Germany. A further check revealed that she served as a compliance officer in the Zurich office of RhineBank AG, otherwise known as the world’s dirtiest bank

The likes of you and I cannot “give” to the federal government, as under the Federal Acquisition Regulations this is considered to be a risk for exerting undue influence. But the CDC has established a nonprofit “CDC Foundation.” According to the CDC’s own website [419]: Established by Congress as an independent, nonprofit organization, the CDC Foundation is the sole entity authorized by Congress to mobilize philanthropic partners and private-sector resources to support CDC’s critical health protection mission. Likewise, the NIH has established the “Foundation for the National Institutes of Health,” currently headed by CEO Dr. Julie Gerberding (formerly CDC director, then president of Merck Vaccines, then chief patient officer and executive vice president, Population Health & Sustainability at Merck and Company—where she had responsibility for Merck’s ESG score compliance). Dr. Gerberding’s career provides a case history illustrating the ties between the administrative state and corporate America. These congressionally chartered nonprofit organizations provide a vehicle whereby the medical-pharmaceutical complex can funnel money into the NIH and CDC to influence both research agendas and policies.

The likes of you and I cannot “give” to the federal government, as under the Federal Acquisition Regulations this is considered to be a risk for exerting undue influence. But the CDC has established a nonprofit “CDC Foundation.” According to the CDC’s own website [419]: Established by Congress as an independent, nonprofit organization, the CDC Foundation is the sole entity authorized by Congress to mobilize philanthropic partners and private-sector resources to support CDC’s critical health protection mission. Likewise, the NIH has established the “Foundation for the National Institutes of Health,” currently headed by CEO Dr. Julie Gerberding (formerly CDC director, then president of Merck Vaccines, then chief patient officer and executive vice president, Population Health & Sustainability at Merck and Company—where she had responsibility for Merck’s ESG score compliance). Dr. Gerberding’s career provides a case history illustrating the ties between the administrative state and corporate America.

In the immortal words texted by Binance’s chief compliance officer to a colleague in 2018: “we are operating as a fking unlicensed securities exchange in the USA bro.” (This and other similar morsels turned up in a lawsuit filed by the SEC against Binance five years after the fact, in June 2023.)

To understand Brahma, understand the structure with the easy (though not apt) example of an org chart that depicts a company or an educational institute that is managed by a board of C-Suite executives. - The universe is managed with invisible powers (in Sanatan Dharma) further by Goddess Laxmi as CFO, Ganesha as Product Owner, Goddess Saraswati as CIO, Narad Muni as HR, Goddess Parvati as Chief Compliance Officer, and many more (for better illustration purposes only).

When you have more crimes, you need more cops—and when you have more cops, you find more ways to use them. (In the US, for instance, we consider it normal to have armed police officers enforce compliance with traffic regulations, even though most traffic violations don’t constitute criminal offenses. It’s the equivalent of routinely sending armed police to enforce IRS regulations or municipal building code regulations. It makes little sense, and increases the number of police-citizen encounters with the potential to go badly wrong.)

This culture within FPD influences officer activities in all areas of policing, beyond just ticketing. Officers expect and demand compliance even when they lack legal authority. They are inclined to interpret the exercise of free-speech rights as unlawful disobedience, innocent movements as physical threats, indications of mental or physical illness as belligerence. Police supervisors and leadership do too little to ensure that officers act in accordance with law and policy, and rarely respond meaningfully to civilian complaints of officer misconduct.

A plumber is required to get his calculations right, or hot water will spray all over the place and he will be fired or sued. A soldier must learn to stick to a plan and to remember his training under pressure or he and his friends will die. A business owner must wake up every day and subject himself to the harsh and inescapable vicissitudes of the free market. A journalist or a compliance officer or a bureaucrat, on the other hand, is able to live almost entirely in his head. Are we to presume that this does not matter?

Hi, I’m Bob Howard. I’m a computational demonologist and senior field agent working for an organization you don’t know exists. My job involves a wide range of tasks, including: writing specifications for structured cabling runs in departmental offices; diving through holes in spacetime that lead to dead worlds and fighting off the things with too many tentacles and mouths that I find there; liaising with procurement officers to draft the functional requirements for our new classified document processing architecture; exorcising haunted jet fighters; ensuring departmental compliance with service backup policy; engaging in gunfights with the inbred cannibal worshippers of undead alien gods; and sitting in committee meetings.

A data protection officer (DPO) is an enterprise security leadership role required by the General Data Protection Regulation (GDPR). Data protection officers are responsible for overseeing data protection strategy and implementation to ensure compliance with GDPR requirements.