Predicting a “time of extraordinary change” in the post-pandemic world, former FBI Director James Comey advised compliance officers their most important role will be to foster an ethical culture at their organizations. Comey’s comments came Tuesday in a prerecorded video message to kick off Compliance Week’s “Financial Crimes Risks, Trends, and Proven Practices” virtual conference.
“I’m sorry for all the pain and anxiety all human beings are experiencing right now, but I also know there’s a special load that’s landed on you all,” began Comey in his 13-minute address.
He continued by acknowledging the unique challenges compliance practitioners are facing. “Your people are not only all over the place working in different environments, but they’re in very stressful environments: Worried about their families, their future, all the stresses that everybody has laying on them today—and that’s compliance risk,” he said.
Comey twice said he hoped everyone’s executive leadership “gets it”: the value of the compliance function not just now but in the not-too-distant future.
He itemized the compliance and security risks of today’s business world: how the era of nontraditional working from home has led to a conflation of domestic and work stress among employees, giving rise to new compliance risks. “People on the inside are vulnerable to being misused, being corrupted, and also to being kind of dumb when they’re under stress,” Comey mused. Add to that the exponential expansion of institutions’ “attack surfaces” due to remote work, coupled with higher demands from regulators to rise to the growing challenges posed by cyber-criminals, and it’s safe to say compliance officers’ jobs “matter more now than ever,” Comey emphasized.
With that theme in mind, Comey advocated for compliance practitioners to seek out the best resources and technologies their institutions have to offer.
“You need to use technology to find indicators of financial crime risk; to pop flags when somebody is going sideways in a way that the company will be deeply sorry about, and, of course, asking why you didn’t spot that after it happens,” Comey said.
He predicted the decade ahead—akin to the Roaring Twenties following the 1918 flu pandemic—will be both exciting and terrifying. For compliance professionals specifically, it will introduce an extraordinary breadth of new challenges, Comey forecasted.
“… Expanded facilities, new employees, new technologies, new supply chains, new partners, new competitors, new regulation as a new government at the United States federal level takes over. … That roaring decade is ahead of us, and your work is going to be that much harder,” said Comey.
A compliance officer’s remit includes identifying bad actors, building a robust training program, and creating mechanisms to spot problems before they arise. But above all else, Comey said, the job is about fostering culture.
“Culture goes bad the way the air goes bad. You can’t see it. You can’t feel it, especially when you’re on the inside,” he analogized. “Your job is to be that detector.”
While Comey more or less likened compliance officers to thermometers—in charge of continually checking the temperature of workplace culture—he also suggested business leaders need to be the thermostats: the ones setting the temperature.
“People watch leaders the way that children watch parents, and they’re shaped by it. And so, your mission is to get the help that you need from your leadership to send the signals that reinforce a healthy culture,” Comey advised.
In no uncertain terms, Comey emphasized that without culture, the rest is futile. Culture is the foundation upon which all other mechanisms and controls, which he compared to “electrified fences,” stand or fall. For this reason, he encouraged attendees to nurture culture by engaging their leaders and keeping a discerning eye on a culture’s seasonal changes.
“You can have all the electrified fences you want. If you have an unhealthy culture in the middle of them, they’re not going to do you any good. People will find ways over them, around them, under them. You build the healthy culture first,” he stressed.
Comey will also keynote Compliance Week’s National Conference (May 11-13), which will go virtual for a second consecutive year.