CCOs As Superheroes: Compliance SWAT Teams

by Michael Volkov
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superheroes4Forgive me for this column in advance but I had to chuckle a little bit when I read that JP Morgan was creating global compliance SWAT teams who, on a moment’s notice, would travel around the globe to respond to compliance emergencies.  I know I have written on behalf of Chief Compliance Officers and the important role they play in every company, but I was not ready to place them in the category of global superheroes.

I have an image in my mind of helicopters used for Special Forces missions lowering CCOs on ropes (with laptops, IPads, calculators and other equipment, I guess) to corporate offices in faraway places to respond to a compliance emergency.  JP Morgan’s latest announcement is serious and being marketed as part of its new compliance initiative.  But it borders on some far-fetched notions and generalizations about compliance.

Companies face important decisions and take important steps every day to respond to issues, especially when they face so-called emergency or crisis situations.  The idea of a global SWAT compliance team is interesting, and if carried out correctly, may even prove productive.

On the other hand, I have some questions about the benefits of such an approach.  If anything, the idea of a centralized SWAT team runs counter to the notion of spreading compliance resources around the globe and embedding operations and resources into company operations in specific regions, countries or even areas within countries.

Compliance officers fight every day for more resources and usually want to embed the personnel in locations where compliance has no footprint or a small footprint.  The creation of a global SWAT compliance team may be appropriate so long as it does not come at the expense of staffing and resource needs for local compliance functions.

There are two trends here at issue.superheroes3

First, the need to place compliance personnel locally is built on the assumption that personal contact and interaction with local staff is always a good thing and should be promoted in a compliance program.

Second, the need for global standards and compliance policies and procedures.  Companies are integrating compliance programs across divisions and regions to standardize many policies and procedures within the entire global organization.  Global companies are recognizing that it is not a good idea to have separate compliance programs for North America, Asia, Europe, the Middle East and Australia.  There are significant benefits to creating a global program.  That is not necessarily inconsistent with the first idea but the distinction is important to make.

superheroesIn all seriousness, JP Morgan’s program may have some positive benefits but the devil will be in the details.  It will be interesting to see exactly what the SWAT team will be responsible for doing.  Moreover, there may be a number of functions that the SWAT team can complete using technology which may not require travel around the globe (in helicopters or airplanes).  Nonetheless, I am a little skeptical that this announcement is more for show than for real, but I can be proven wrong.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Michael Volkov, The Volkov Law Group | Attorney Advertising

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