The Man From FCPA believes that most English folks have gotten past the fact that Americans revolted away from England several years ago. Indeed, I am married to an English woman and have English in-laws. At least I can claim to be the beneficiary of a “Special Relationship” between our two peoples. I’ve found that the English are much less forgiving, however, when it comes to their football clubs (soccer teams for the uninitiated Yanks). American ownership of English football clubs is beginning to demonstrate that there are very different ways to think about your relationship to your customers. The growing pains have brought some important lessons to the compliance professional.

Most U.S. sports teams’ owner have their clubs as trophies to show off and to allow them to hobnob with other billionaires in very rarified air. Many use these money-making machines as simply that: ATMs to take out the money for personal use or use in their myriad other business interests. Football club ownership in the United Kingdom, however, has been much more locally controlled, with the ownership in sync with its fan base. One report termed it as “deafening cultural dissonance.” The article ended by noting “There is a lot, still, for both sides to learn.”

This is one of the key issues for any compliance professional, working through the cultural dissonance, literally across the globe. In emerging countries, a top-down enforced compliance program based upon the Ten Hallmarks of an Effective Compliance Program, may not go over too well. If you communicate to your business development teams on the ground, however, that by having an effective compliance program in place it may make your company more marketable to either U.S. or U.K. companies, the argument may well resonate. One of the key challenges of any compliance practitioner is to make compliance relevant outside the corporate office in the United States. Operationalizing compliance can be one way to do so.