Technology and Compliance: The Magic Bullet?
It has become appallingly obvious that our technology has exceeded our humanity. – Albert Einstein
The human spirit must prevail over technology. – Albert Einstein
Technology is nothing. What’s important is that you have faith in people, that they’re basically good and smart, and if you give them tools, they’ll do wonderful things with them. – Steve Jobs
Believe it or not, these quotes concerning technology apply to the ethics and compliance profession. Bear with me as I attempt to apply these interesting and thoughtful quotes to compliance.
We all are living in an era of rapid technological development – everyone understands that basic point. Even in a small way, we can observe the impact in ethics and compliance. Start with the simple transition from “paper” compliance programs to an operationalized program that increasingly depends on the effectiveness of automated solutions.
Do not get me wrong – I am not talking about the famous computer system, “Hal,” in Space Odyssey 2001. (See Clip Here). But I am addressing the compliance profession’s increasing reliance on automated solutions and the impact it is having on compliance programs.
A recent NAVEX Global (Here) report identified the two most significant predictors of compliance success – senior management buy-in and support AND automation.
At the recent ACAMS national meeting in Las Vegas, I was struck by the language surrounding each and every vendor in the exhibit hall touting its company’s “machine learning” and “artificial intelligence” functions in its product offering. Assuming that these claims are accurate (and without getting into the real definition of these terms and the specific application to the products), it is interesting that the compliance profession is addressing the “ethics” of artificial intelligence and so-called new technologies, and in particular the impact of these technologies on privacy concerns.
Before I get lost in the trees, let’s return to the forest perspective. There is no question that automation has and will continue to improve the capabilities of compliance professionals. The compliance industry is quickly integrating into a single compliance “platform” or “dashboard,” consisting of critical functions: (1) incident data; (2) employee concerns; (3) conflict of interest; (4) culture monitoring; (5) third-party risk management (consisting of representatives and vendors/suppliers); (6) training; and (7) policy management.
These are important developments and everyone should welcome these capabilities and quickly integrate them into your compliance program operations. Once these solutions are implemented, compliance professionals are freed from the burdens of a paper compliance program and able to dedicate themselves to other important functions.
And this will be my important point – no matter how you define ethics and compliance, or even get into the question of whether a corporation is a “person,” the ultimate issue is that a company’s most important asset is its “people,” meaning its board, senior management and employees.
I am not one who agreed often with Steve Jobs or admired his interpersonal skills, but his quote is exactly right. Underlying Jobs’ quote is that a company’s performance ultimately depends on the company’s mission, its ability to inspire and the performance of its employees. In this respect, compliance plays a critical role – managing and monitoring the company’s ethical culture. For compliance professionals, this translates into one overriding priority – the company’s ethical and compliance culture.
While I have consistently argued for greater attention to this issue, I recognized that many ethics and compliance professionals have been bogged down in antiquated “technology,” resembling The Flintstones (see clip here), and suffered under paper compliance functions. Luckily, the compliance industry is addressing these needs and bringing efficiency to the compliance function.
As these solutions are embraced, compliance officers have to exercise care in considering how to re-allocate their time and resources. In doing so, it is my hope that managing a company’s ethical culture will rise to the top of the list.