Over this past weekend, on one of the busiest days of the travel year, at one of the busiest airports, primary hub to one of America’s top two airlines, there was a 12-hour power outage that shut down all inbound and outbound traffic from Atlanta’s Hartsfield Airport and all power inside the airport. The cause of the power outage has been reported to be “fire in a crucial piece of electrical equipment.” While a fire in electrical equipment is a known risk in any business, what makes the Hartsfield power outage noteworthy is there was no backup system in place. Former Secretary of Transportation, Anthony Foxx tweeted “There is no excuse for lack of workable redundant power source. None!” A spokesman for the local power company, Georgia Power, admitted in a statement noted there was a need for “some redundancy.”
Interestingly this massive travel disruption speaks to a key component of any best practices compliance program, multiple redundancies. Certainly, the documentation of your compliance actions is critical when a regulator comes knocking but having your actions documented allows review and approval by compliance subject matter experts in your compliance function and more senior management, up to and including the board of directors as appropriate. Internal controls also act as a backup when multiple levels of approval are needed to approve and confirm an action. Internal controls can act as both a detect and prevent mechanism in this manner.
Backup is also the reason your compliance program should have multiple levels of review and approval around your high-risk areas. A committee of senior managers who review agents or other third-party risk can act as a backup if something, someone or some entity somehow slips through the cracks. This is the same at the Board level, it can all act as a backup. In the FCPA realm, such redundancy can help your company from engaging in potential criminal violations. The next time, someone in your organization asks why there are backups and redundancies in your compliance program, point them to Atlanta.