Compliance Challenges

“I am aware that being in compliance is not for the faint of heart.”

Hui Chen, new compliance expert for the U.S. Justice Department (DOJ), made that statement in a recent interview with ethics and compliance advisor Laura Jacobus (transcript posted by the Ethics & Compliance Initiative; see link below). Chen went on to say that [compliance officers] must have “backbone, good judgement, and excellent people skills.”

Jacobus, Chen, and Andrew Weissmann, chief of the Fraud Section of the DOJ’s Criminal Division, touched on several topics in the interview, including the challenges facing compliance professionals.

Among the challenges, according to Chen:

Cost center role

Compliance is not a profit center, and it may be perceived as a cost center that ties the hands of profit centers.

Says Chen, “Starting from this somewhat disadvantaged position, compliance has to find ways to win and maintain the trust, respect, and cooperation from the rest of the company, and to do so without compromising its obligations or integrity.”

Dispersed authority and responsibility

Compliance does not work in isolation; it relies on other functions to implement controls.

“The controls must be embedded in almost every aspect of a company’s operations that are not owned by compliance,” Chen acknowledges. “For example, compliance can identify issues in a company’s financial controls, human resource (HR) processes, or sales strategy, but compliance does not have ownership of these functions and processes. In this example, without the commitment of finance, HR, or sales leadership, these issues cannot be remediated.”

Cultural translation

Businesses are becoming increasingly global, and “compliance officers often find themselves on the front line of this cultural experience, and have to help their colleagues not only understand the compliance expectations, but ways to navigate towards these expectations in societies that are not necessarily accustomed to these behaviors.”

Chen started her compliance career as an on-the-ground compliance officer. She says she will be mindful of the challenges facing compliance officers as she fulfills her DOJ responsibilities to advise Fraud Section prosecutors.

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ECI. “DOJ’s Andrew Weissmann and Hui Chen Talk Corporate Compliance in Exclusive Interview, (Press Release),” February 1, 2016.

Jacobus, Laura. “DOJ’s Andrew Weissmann and Hui Chen Talk Corporate Compliance in Exclusive Interview,” ECI Big Ideas Blog, February 1, 2016.