Welcome back to Sherlock Holmes week. It does look like I will get carried away and it will become 10 days of Holmes and compliance as I am rereading the first volume of Holmes, The Adventures of Sherlock Holmes and I find them as great ways to introduce compliance topics. I have been using a Holmes story each day to illustrate a compliance lesson or issue. Today we use the Sherlock Holmes short story, The Man With the Twisted Lip. This story is notable as it is the earliest examples of the play-fair mystery in which the clues are presented to the reader as they are presented to the detective. Perhaps more tantalizingly, there is but the slightest hint of romance between Holmes and Mrs. Neville St. Clair, which is extraordinarily rare in Holmes stories.

The story centers Neville St. Clair, who is missing. His family’s home is in the country, but he visits London every day on business. One day Mrs. St. Clair also went to London. In a notorious section  of town, she saw her husband above an opium den. She called the police, but they did not find him. The room behind the window was the lair of a dirty, disfigured beggar, known to the police as Hugh Boone. Mrs. St. Clair noticed the beggar had a box of wooden toy bricks her husband had promised to buy for their son.

Hugh Boone was arrested at once but said nothing, except to deny any knowledge of St. Clair. He also resisted any attempt to make him wash. Holmes was initially quite convinced that St. Clair had been murdered and that Boone was involved. But several days after the disappearance, Mrs. St. Clair received a letter from her husband in his own handwriting telling her not to worry. It included his wedding ring as an early ‘proof of life’. Holmes and Watson then went to the police station where Hugh Boone was held and washed his face, revealing Neville St. Clair.

Mr. St. Clair has been leading a double life, as a respectable businessman and as a beggar. His takings were large enough that he was able to establish himself as a country gentleman, marry well and begin a respectable family. His wife and children never knew what he did for a living, and when arrested, he feared exposure more than prison or the gallows. As there was no murder, he was released. All concerned agreed to keep St. Clair’s secret as long as no more is heard of Hugh Boone.

It is this story of how Neville St. Clair used begging to pay off debts and then improve himself which leads to today’s focus on continuous improvement. The lesson is that continuous improvement can come in many different, shapes, sizes and packages. As with all things compliance, you are only limited by your imagination. Have you ever thought about a tech implementation as a way for continuous improvement? Probably not but it is also a way forward for continuous improvement.

Execution is where the rubber meets the road in compliance. For any Chief Compliance Officer (CCO) or compliance practitioner, having not only an effective tech strategy for compliance but one that is executed is critical. This is where a tech solution for compliance can step in to make a very big difference. Typically, a CCO comes from the General Counsel’s (GCs) office or has some type of legal or other non-tech professional backgrounds. While resources and head count are always an issue for a CCO, work on administrative matters can also put a strain on a corporate compliance program. One of the first issues a CCO should consider is having an automated program to handle the administrative tasks and then couple it with measurable data which allows a CCO to move from a detect mode to preventative and even prescriptive. With this consistency, you can deliver a more robust risk management strategy to senior management and the Board of Directors.

Another challenge for many CCOs is how to interpret the data they receive from a tech solution. In short, what does it all mean? The key is to work backwards to figure out not only what type of metrics will be generated but what a CCO might need going forward. You want to be very clear on what the data your program is apprehending in terms of reporting and what is needed to implement the compliance program going forward. You should begin your analytics at the transaction level and roll them up in to a state where you can see  a larger picture to make a holistic appraisal. While it is obviously important for a tech solution implementation to be successful, if you work towards it from the start it can help to make things richer and more succinct at the conclusion of your project.

Next, consider system deployment. This means both adoption of a tech solution and its continued and even expanding use. You should begin by putting the compliance program into the tech solution and then move to train your compliance team on the solution going forward. This training works not only for the compliance professionals present at deployment but those who might come into the corporate compliance function after deployment. This continuous implementation, working to grow and expand the use of the tech solution to not only cover the original issue(s) but expand the tech solution to meet new challenges.

This approach has some very significant and positive implication for the compliance professional. This is another way to talk about continuous improvement in a compliance program. You should take care there is a 100% attention rate in order to stay relevant within the organization. Ensuring there is continued coverage to support not only from the home office level but also the county level, essentially partnering with operations to ensure that as it grows the tech solution is right sized for them. Even if you have a small or medium sized compliance function, you want to be able to scale your compliance program down the road into bigger solutions for compliance program. In such cases, this can work to right size the compliance program and appropriately identify and manage high risk vendors, delivering additional reports with the tech solution configured properly so that you can get additional reports as needed. And this is all part of continuously working your tech solution to ensure it is right sized for your organization.

Such an approach uses the subject matter expertise (SME) of the tech solution provider to help the compliance professional come up with a more effective compliance program. For the compliance professional it is expanding out their reach and scope through the use of not only this tech SME but with the information from their own compliance program to create greater efficiencies and effectiveness.

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