Building an Effective and Integrated Compliance Department

By Christian Schunk

In the international development sector, program implementation and business development are often viewed as the driving force behind an organization, with compliance relegated to a bench role. In parallel with this view, compliance practitioners are viewed similarly outside of their community — as process and rule-obsessed, whose main tasks are reviewing requests and training staff while often acting as a roadblock to programming or business development goals.

The goal of this piece is to reimagine compliance in international development away from this unfavorable stereotype into a vision that elevates compliance beyond a necessity to a driver of excellence and growth. To do that, there must be a focus on oft-neglected pillars of compliance: problem-solving and customer service. Effective compliance depends on establishing a culture that values a process-driven approach, emphasizes strong written internal policies and procedures, maintains internal reporting mechanisms, actively monitors regulatory updates and provides frequent training. However, these components are insufficient in creating a truly dynamic compliance program that places it on equal footing with programming and business development.

Problem Solving

Maintaining an effective problem-solving mindset demands an understanding of the larger context — an ability to think critically, and more importantly, creatively. This is especially true in the international development context, given the constantly evolving set of regulations we must navigate and the shifting operational environments where our activities are implemented. Having a strong problem-solving mindset noticeably separates top-notch compliance professionals from others.

As compliance professionals, how do we encourage this mindset within our teams?

The tone must be set at the top and a leader’s first questions should be the following:

· How do we solve this problem?

· How do we implement the suggested approach?

· Can we find alternatives that still achieve our goal?

If your compliance teams’ answer to novel approaches or imperfect situations is “You can’t do that!” without finding ways to creatively work within the regulatory limits, then they’re doing the organization a disservice. The best international development compliance professionals don’t simply regurgitate 2 CFR 200 and AIDAR, but know how to interpret the regulations keeping in mind their intent.

In addition to promoting creativity from the top down, it is critical to build a team with individuals who are naturally and intellectually curious. Consider hiring individuals who have less formal compliance experience but who are innate problem solvers and who relish the challenge of disentangling complex and nuanced situations. In fact, it is often easier to hire folks with a creative problem-solving mindset and have them learn regulations than it is to hire folks who are well versed in regulations but view things in black and white and struggle with nuance.

Customer Service

The second neglected pillar of compliance is customer service. The primary clients of compliance teams in international development are other units within an organization and external donors. This means setting and adhering to clear response times and being able to plan accordingly. When customers send you requests, they should expect a substantive response within a standard time frame. Utilizing a problem-solving mindset to address challenges and eliciting feedback through periodic surveys to measure the team’s effectiveness and opportunities for improvement is one way to drive responsive customer service. This also means building relationships with your customers so that they see you as a resource rather than an antagonist.

Strong customer service also encourages other teams to actively engage with their compliance colleagues when complex issues arise, instead of waiting until they become crises that threaten the organization.

Lastly, a focus on customer service means finding engaging ways to communicate compliance principles in ways that are easily understandable and relevant — whether by eschewing the dreaded slide deck, holding informal meetings on easily digestible concepts, developing practical tools and templates that staff can use in their daily work or using humor to illustrate complex regulations. These approaches also encourage compliance teams to develop a wider range of useful skills.

There are myriad of vendors promising a variety of pricey compliance systems. While helpful, having a creative, problem-solving mindset and an effective customer service ethos are more critical to building an effective compliance team. By ensuring that a compliance program includes these two pillars, an organization not only minimizes its operational risks, but also improves its service delivery, strengthens relationships with its clients and increases the impact it has on the communities it serves.

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