Let it grow...

In his great book: Antifragile: Things That Gain from Disorder, Nassim Nicholas Taleb beware us of making things too fast. He is saying that like Mother Nature needs time to grow the tree we need to be patient and let things grow.

If you thing that has nothing to do with compliance job, think about effective implementation of compliance programs. The nature of the business is fast, ever-changing and very dynamic. You need to react proactively and very rapidly in order to satisfy your management board with the appropriate program.

On the other hand, you need time … to learn all law and regulations, to validate and assess all risk and related possible disorders, finally … you need to prepare good program and all ‘marketing’ around it.

This is what you need to achieve your goals:

Step 1. Appoint a reliable compliance program owner – you need person with right attitude and knowledge to let him/her act independently once the program will be in force

Step 2. Form a working group – don’t even think of acting along! You need buy-in from the business, process owners, colleagues from Law or Audit Departments, etc.

Step 3. Identify “core elements” – draft a plan, be ready to present how you want to accomplish your goal and what will business benefit from this. You don’t need to be very specific yet. It is time to frame your thoughts and prepare others for changes.

Step 4. Create compliance program document – now it’s time to work with the whole group on the complete and holistic program. Think about program objectives, list all related risks and how you plan to mitigate them, plan all actions, ideally think of annual plan, as well as 3 year goals. List all resources you need and never forget to complete your program with governance framework. You need to know at the very beginning what governance bodies you need, how issues will be escalated and who will take care of what. This will take you some time, but it’s ok, remember that the flower is not growing faster just because someone sets it unrealistic deadline… Flower as a tree needs time, and you need time as well to be ready for a next step.

Step 5. Roll out the program – Mother Nature teaches as not only that plants needs time to grow, She is also teaches us that to be alive they need to be cared of. You program will need that care as well. You need to stay focused on your objective, monitor how you progress, regularly train people, alter your plans if there is a need, and report back your progress.

Step 6. Keep it rolling – once your program is in place, don’t think that you job is done. It is time to celebrate achievement, for a while, … and get back to work which is even more complicated. From now on you will no longer have that managerial focus on the program itself. It will require very organised and systematic work to constantly develop policies, stay up-to-date on regulatory changes and refresh compliance program and its measurements. It might be that after a while you will need to change whole thing completely and replace it with something new. This is again Mother Nature approach. Once the time comes, a tree or flower fade away, and there is a place for a new plant.