One of the puzzling aspects of compliance is that it means vastly different things across industries. What compliance means to a bank is very different from what compliance means to a drilling company.
I think the reasons are obvious: regulatory requirements.
In a highly regulated industry, there will be a greater focus on complying the regulatory mandate. A broker-dealer compliance officer is going to be focused primarily on the FINRA rules for broker dealers. An investment adviser compliance officer is going to be focused on compliance with its regulatory scheme. A drilling company is going to be focused on a different set of rules.
I see the difference in the junk mail I receive each day. I get flyers on FCPA compliance, OSHA compliance, Clean Water Act compliance… Someone is clearly checking the compliance box without thought to the substance behind it.
Most compliance as a discipline starts with the Department of Justice’s Sentencing Guidelines. That is a good base framework. But in regulated industries, the regulations go into much more detail about what needs to be done. It’s not about right or wrong, but what the government says you have to do.
Sources:
- Noooooo! Panic in the Compliance Office by Adam Turtletaub in SCCE’s Compliance & Ethics Blog
