The Accidental Compliance Professional

A Series of Miscalculations

I did not see a couple things coming. Larry was big, but he was also fast. I thought that I would have a big lead, but Larry was just 3 feet behind me. This was an important fact that I didn’t know. The first problem this caused was not a big deal―Marc could not hit Larry with his water balloons without getting me wet. The more I ran, the wetter I got. I am pretty sure the next seven water balloons hit Larry. The last seven took a while longer to get airborne. The guys had to shift them from their non-throwing hands to their throwing hands. This meant they weren’t tossed until Larry and I were well past them. By the time I reached the door, I was soaked. They got Larry pretty good, but also the door, walls, and linoleum floor of the lobby. The fact that the floor would get slippery was another miscalculation of mine.

Before I get to the utter disaster part, I have to tell you there was one more Mark involved―Mark with a K. He was stationed at the door and was going to shut it on Larry to give me time to get away. Through the sea of water that flew through the air, I noticed an odd look on Mark’s face. He seemed a little surprised, perplexed, and concerned.

I later realized that it’s important to read the nonverbal expressions of others, particularly in difficult situations. Mark had information I did not have. Mark sent me a clear signal that something was going wrong or about to go wrong, but I ignored his signals and trudged on with the plan. Man, I wish I would have reacted better. I wish I would have “listened” to him. If I had just ran through the door as planned, all would have been fine.

Instead, I thought Mark was chickening out, so I grabbed the outside of the door handle as I flew by and somehow closed the wood and glass door very fast. I did not delegate and trust―I delegated and micromanaged. The door hadn’t fully closed when Larry hit the wooden frame, and the entire glass section exploded.

I started running away from the scene as planned, toward the door that led out of the lobby to freedom. When I got to the door, I held it in my hand and paused. If I went through that door, I might avoid being associated with the prank. Instead, I looked back at Mark. He was bent over Larry, who had tiny bits of glass stuck in his arm. Larry had slipped on the water, fallen down, and glass shards went into his arm.

Do I stay? Do I go? I wondered. It wasn’t long before I had an answer. Across the lobby from the cafeteria was the dorm supervisor’s apartment. She opened her door right then and looked at me. I looked back at her . . . then I let go of that door to freedom. I was going to stay and help make this right. We walked over to Larry, helped him up, and went to the dorm supervisor’s apartment. She and I picked the glass out of Larry’s arm. I mumbled something about being so sorry, it’s all my fault, and some other stuff that she would remember more clearly than I. She did not say much, she just listened. Then I took Larry to the hospital where he got about 20 stitches, if I remember right. Whatever the number was, it got bigger every time Larry told the story. Young women heard 20, then 30, then eventually Larry told them, “Yeah, I got 40 stitches in my arm.” I tucked this away in my pitifully empty bin of good things that came from this bad situation―Larry got more attention from the girls. Like he needed it, the dude was an Adonis.

Larry was a little banged up, but thankfully okay, and I learned a few things from the experience that I would eventually use in compliance:

1. I should have expected the problems long before they occurred.

2. Changing plans, particularly during difficult moments in a process, is generally not a good idea.

3. When you see something that doesn’t add up, stop what you’re doing and start asking questions.

The Stolen Sign Incident

That prank wasn’t exactly the only thing I did wrong in college. On another particularly bad day, I was in my dorm room studying when someone flung open my door, saying, “Come quick, Tom is hurt!”

Yes, Tom was also involved in this story. I walked across the hall into the study room, which had been converted around 30 minutes earlier into a boxing ring. Two guys had gloves, all the chairs were up against the wall, and people who had been studying were now cheering on one of the two pugilists. They were until one of them, my roommate Tom, fell backward and hit his head on a chair.

I helped Tom back to our room. Apparently lots of phone calls were made during our short walk, because there was a stretcher, some attendants, and a campus officer waiting for us. And in the doorway was our dorm supervisor, just taking it all in. They loaded my roommate onto the stretcher. Then the officer added to my stress.

“Whose sign is that?” he asked.

Oh crap. I was almost once again through the door of freedom, on the way to the hospital with my roommate―but no. The sign he was pointing to was previously above the door of the dean of Agriculture & Natural Resources’ office. Now the sign hung mere feet from me in my dorm room.

“The sign is mine,” I told him. Well not exactly mine, it was the dean’s sign.

Then the officer started reading me my rights. Instead of listening, I interrupted him.

“I have admitted it’s my sign. My roommate is being wheeled out on a stretcher. Can we handle this another time?”

It shouldn’t have worked, but it did. The officer let me go and I headed out of the room just behind the stretcher. As I passed the dorm supervisor, she said rather quietly (but loud enough for me to clearly hear), “If you need any help, let me know.”

My roommate turned out to be okay, but I was later called into the campus police department where I was introduced to two guys wearing dress pants, white shirts, and over-the-shoulder gun holsters—with actual guns. They took me to a room with a two-way mirror. Then they questioned me about the sign for what seemed like an hour.

I was expecting a punishment, so finally I said, “Look guys, I admitted to having the sign. I know this is wrong. Why are we still talking?”

“Well, Roy,” said one officer, “three days before this sign was stolen, the building it was in was set on fire. Then 11 days after the sign was stolen, the building was set on fire again.”

I immediately leaned toward them and said, “You guys have got to believe me. I’m telling you . . . I had nothing to do with that.” Shortly after, they stopped asking questions and said the meeting was over. I had no idea why. I was hoping it was because they believed I was telling the truth.

I went back to my dorm and spent around three weeks freaking out before I slowly started to let it go. I was never written up for having the stolen sign and I never heard from the officers again, but this story would come up in a very peculiar way with my dorm supervisor.

“You got into trouble. You handled it well.”

About six months later, a call went out for people to apply to become resident assistants for the following year. I thought: I could do that. So, I applied and went through a first round of interviews. There would end up being many rounds of cuts—down from 110 applicants to seven people for the open positions.

The last cut was a one-on-one interview with, you guessed it, the dorm supervisor. At this interview I learned a lesson I will always remember, have used repeatedly, and will take with me to my grave. I have shared this lesson with many people throughout my career. Frankly, I think it may be the most important lesson I ever learned in preparation for a job as a compliance officer.

The dorm supervisor had seen me at my worst, and I felt comfortable being completely honest with her. I had repeated the standard “I can do this job” answers enough through my many rounds of interviews, and I couldn’t continue pretending there wasn’t an elephant in the room.

“What am I doing here?” I asked her. “I screwed up and got a guy hurt. I got caught with a stolen sign. You were there! How the heck is it that I am sitting here with you? Why am I still in this process?”

I wanted to be honest and I wanted her to be honest―more than I wanted to become an RA. Man, does it feel good when an honest conversation comes together.

“Well Roy, you got into trouble,” she said. “You handled it well. If you become an RA, a big part of your job will be helping some of your guys when they get into trouble. We think they are going to get into trouble. We think you can help them with that.”

So, I made the last cut and became an RA, and I loved it. I learned a ton about helping people in general and especially when the crud hit the fan. It took me years to realize how much my dorm supervisor taught me that day, but eventually I figured it out. I have used what she taught me to help many people. I have made better decisions about people because of her. And I became much more understanding of people who had problems when I was a compliance professional.

As you work with others who make mistakes, remember your unfortunate incidents. What do you have to lose by showing some empathy for others as they go through a difficult audit, investigation, and disciplinary process? My dorm supervisor not only did not penalize me, she put me in charge of a bunch of guys like me the very next year. That seems ridiculous, even to me, but I know she was right to do it. It seems ridiculous only because it’s not often done, not because it shouldn’t be done. It goes against conventional wisdom. I knew I learned from my mistakes and could help others, because I had been there. She put me in charge of a bunch of college students because I was a screw-up who handled my mistakes properly. I am currently trying to find this dorm supervisor, so I can tell her what she means to me and thank her for her belief in me. I want to tell her the rest of my story, too: I eventually became a cofounder of the Society of Corporate Compliance and Ethics. I went on to write a book about this sort of thing. You were right to do what you did.

My advice to you and every compliance professional is to be the dorm supervisor for your company. Try to help prevent your people from getting into trouble, but be as understanding as you can when they do make mistakes. Most of them will mean well—plenty of well-meaning people make mistakes. Think whatever you want to think about the truly unethical people. Hang them from the highest tree if you want. But remember, always remember, the vast majority of your people don’t know enough about compliance and ethics to be error-free. Embrace your organization and all its flaws, as you should embrace your own. Do it for yourself, your peace of mind, and the people you serve.