Following the recent COVID-19 outbreak within the Miami Marlins baseball team, Major League Baseball (MLB) Commissioner Rob Manfred announced that the MLB would be requiring each team to designate a compliance officer. These compliance officers are responsible for making sure players and team staff adhere to the League’s health and safety protocols, as detailed in its manual for play during the pandemic, including new guidelines following the recent outbreak.
While it’s not clear if the MLB provided teams a sample detailed job description, I have to think the position carries some of the same duties of the CCOs and risk officers we work with every day – ensure their firm’s comply with outside/internal regulatory requirements. Which got me thinking – what advice could we share that these newly appointed compliance officers would benefit from?
So, in the spirit of sharing what we’ve learned over the years from working with countless CCOs, below are three truths to running a successful compliance program:
Truth #1: You Can’t do it Alone
By many, 2020 has been seen as the year that the job of compliance officers grew even wider. Now, not only are risk and compliance officers expected to oversee the implementation and adoption of some large-scale regulatory changes, but also to deal with cybersecurity risk assessments, emerging new product areas such as cryptocurrencies and the potential for enhanced personal liability. As a single individual, or small team, you can only do so much.
It’s in times like these that middle managers (or team coaches) can help push the compliance agenda forward. Ask them to publicly thank one or more of their employees who have done something to support or promote the compliance program. By asking them to publicly acknowledge their employees/players for compliant actions, they learn that (1) they can win points for supporting compliance and (2) leadership thinks compliance is important.
Truth 2: Compliance Training is Key
The MLB’s schedule calls for each team’s 60-game schedule to be played within 66 days, which leaves very little room for one very important step in building a culture of compliance – training. Employee training is a huge step towards a culture of compliance because it helps each person in your company understand what is expected of them and their unique part in the compliance process.
You can make training more practical by giving employees scenarios and specific processes for how they should react to situations they may encounter every day. This training should also communicate what consequences exist if they don’t follow the compliance program and take shortcuts. Taking a page out of the FINRA/SEC-registered CCO’s rulebook – it’s important to explain the disciplinary guidelines and then make sure that you enforce them consistently.
Truth 3: Change is the Name of the Game
If there’s anything that this year has taught us, it’s that change is inevitable and we all must be ready to adapt at a moment’s notice. Changes in regulations will happen, and implementing these changes is essential. This is true for both the MLB and financial services industry.
The fall of great companies can almost always be traced back to their inability to adapt to change; be it internal or market-based. Providing employees with background and an understanding as to why certain changes are important is a good place to start. This will keep everyone informed and lead naturally into building a sound culture of compliance.
The role of compliance is constantly evolving. The topic is no longer confined to the financial and insurance industry, it has become the cornerstone of organizations across all industries. Compliance and risk management covers a wide range of business areas, whether it’s HR data privacy, website compliance in online marketing or, yes, even the MLB.