The Accidental Compliance Professional

  1. Copyright

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    The Accidental Compliance Professional: Lessons Learned from 23 Years in the Industry is published by the Society of Corporate Compliance and Ethics, Minneapolis, MN...

  2. Dedication

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    This book is dedicated to my parents Marge and Jud Snell, who were flawed, honest, ethical, trusting, and respectful of others. When I wonder why I have found such a comfortable place in the compliance community, I always think of them. They gave me a strong foundation of humor and integrity, which has helped me in every aspect of my life...

  3. Acknowledgements

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    I want to thank my greatest mentor Marc Dettmann, who taught me many of the lessons that you’ll find in this book. I want to thank my family―Julie, Jessica, Abbie, Erin, and Anna―for helping me become a better person. Much credit for this book goes to Karen Latchana Kenney, who essentially cowrote it and made it so much better. There are way too many compliance mentors to thank, such as Dan Roach, Debbie Troklus, Sheryl Vacca, Margaret Hambleton, Odell Guyton, Joe Murphy, and Donna Boehme, to mention a few. Most of all I want to thank every compliance professional who...

  4. Foreword

    The Accidental Compliance Professional  | Author: Dan Roach  | March 2019 

    I may know Roy Snell better than anyone, except his closest family members. We have worked closely together professionally for more than 20 years. We both share an obsession with rusty old tools and machines, which has meant hundreds of hours together at estate sales, swap meets, auctions, or old farms trying to score real or perceived treasures. Moreover, we both share a passion for the wilderness, which led to a personal partnership for the past 10 years―together we own a remote northern Ontario lake property 50 miles from the nearest pavement or power pole, 12 miles from the end...

  5. Introduction. One Sentence Changed Everything

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    It was probably around 1995, the midpoint of my career. I was managing close to 30 people who determined what doctors should charge for their services. CEO Marc Dettmann and I were walking down the hallway and he had a long document in his hand. It was written by someone in the enforcement community—probably a few someones. The document was a settlement between the enforcement community and a prominent organization. Of all the rambling pages of legalese, Marc had turned to one page and was pointing to one sentence...

  6. Lesson 1. How to Handle "The Big One"

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    It’s clear that the person I’m sitting across from at the conference table is upset with me. He’s not just upset; he’s furious. A few other people are in the room too: my employee and his boss. However, from the moment we started this discussion, it was clear that the very angry and intimidating man was on his own. I just needed to hang in there...

  7. Lesson 2. Fill Every Hole That the Rats Might Get Through

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    I once walked into work with a belt and suspenders on. Marc said, “So you’re a belt and suspenders kind of guy?” I really didn’t get the point/joke he was making. Later I figured out that if you have suspenders on, you don’t need a belt. He was giving me the business in a fun-loving way, but as I write this I realize he was wrong―very wrong. The fact that I was wearing a belt and suspenders was brilliant. In fact, I should have had rope, some glue, and duct tape holding up my pants. I should have responded, “What?...

  8. Lesson 3. Study Your Failures to Find a Better Way

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    It was just a couple days past my 17th birthday and my buddies Mike Johnson and Tom Kelch (Mad Dog) were driving with me down a dirt road in the dark. My parents thought we were going to a football game. Instead we were on that long stretch of road, one perfect for joyriding. The car was my stepmother’s—an 11-year-old Delta 88 with only 11,000 miles on it. It was, for the moment, in mint condition...

  9. Lesson 4. College Pranks Gone Wrong

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    “Man, I am going to get you back this time,” Larry told me.*...

  10. Lesson 5. Hit the Compliance Bullseye with Expert Help

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    “Who is the best?” That’s the question my boss Marc Dettmann always asked when we needed to fix a problem. He taught me to respect specialists and how to use them...

  11. Lesson 6. Building Compliance Ambassadors through Influence

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    Let’s start this lesson with a little compliance quiz. First think of the most impressive compliance professional you’ve ever met. You have five minutes to think and then answer the following questions. Now go!...

  12. Lesson 7. Compliance Activism Belongs in a Rodeo

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    I was driving into work one day and got a call from my second-in-command. She was beside herself. The office had been broken into. Computers were missing...

  13. Lesson 8. Get into the Soul of the Machine

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    Early on in my career, a compliance officer at a Fortune 100 company asked me to come give a presentation on “Compliance as a Verb.”...

  14. Lesson 9. That's What I'm Talking About!

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    Jordyn walked into my office one day. “I’ve broken the rule of law,” she told me...

  15. Lesson 10. Sowing Seeds of Compliance around the World

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    Come to Sarajevo...

  16. Lesson 11. Nightmare on the Papaonga River

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    “Oh no. It broke!” said Gene, my friend Dan Roach’s dad...

  17. Lesson 12. The Dangers of Rationalization

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    Writer and philosopher Ayn Rand once said, “Rationalization is a process not of perceiving reality, but of attempting to make reality fit one’s emotions.”[1]...

  18. Lesson 13. Victoria and the Falsified Logs

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    People never seem to know what compliance professionals actually do. It’s very frustrating. They think we create the rules they have to follow, when in reality compliance professionals create the process of following rules others impose on them. They think compliance is all about punishment, when in reality compliance finds problems early so fewer people are punished...

  19. Lesson 14. The Possibility of Being Too Ethical

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    In 2014, former FBI Director James B. Comey gave the keynote speech at our Compliance & Ethics Institute in Chicago. When introducing him, I said that I believed the FBI had one of the best compliance programs of any government agency. Comey thought so too, stating that the FBI was very proud of their compliance program...

  20. Lesson 15. A Guide to Being Delightfully Honest

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    We were at a leadership meeting and the discussion had been a particularly tough one. For an hour or so, everyone was stressed while we worked out a plan to fix our issue. At the end of that meeting, I could see how drained everyone was. I had taken a very strong stand and was pretty passionate throughout the discussion. So, I said, “Other than that . . . I feel pretty neutral about the whole thing.” Then everyone laughed as we got up to leave...

  21. Lesson 16. Fighting Groupthink with Diversity

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    At the 2018 CEI, I gave my goodbye speech to the members of one of the associations I helped build. I was so lucky to have this opportunity to be a cofounder and CEO. However, having to say goodbye was a bit much. It was a surreal moment. What I did to get past the emotion of the moment was to focus on the bigger picture. So I crafted an important message that I could send to those in attendance about the profession and our organization. I wanted to thank everyone involved, but especially paid tribute to the diversity of...

  22. Lesson 17. Independence: Why it’s Critical

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    Accounting is a risk area. Marketing and sales is a risk area. Quality control is a risk area. That got me to wondering: Aren’t all departments risk areas? If all departments are risk areas, should risk managers consider the legal department a risk area? In all my years in compliance, I have never heard anyone ask that question. Given that the compliance profession is so concerned about identifying risks, it seems that the question should have been asked by now and debated. The legal department makes the most complex and important legal decisions of any department in the organization. Some...

  23. Conclusion. Thank YOU for Your Service

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    Leaving SCCE and HCCA has made me think a lot about what these organizations have accomplished in the past 20 or so years. And one thought sticks in my mind―service. Our profession provides a great service to organizations of all kinds, your country, and the world...

  24. Afterword

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    I have been evolving. One of the things I have tried to do better is find people to work with who understand some important task. Then I let them do what it is they do. In other words: I trust them. I particularly like letting people who work in an often micromanaged profession . . . do their job. I get a kick out of telling them: “Cool, let’s do what you said.” I worked with Karen Latchana Kenney on something very important to me―this book, my first book. Karen is my editor. In the process of writing this book...

  25. The Compliance Professional's Credo

    The Accidental Compliance Professional  | Author: Roy Snell  | March 2019 

    This is a list of things I commit to as a compliance professional. It’s not an exact science, an exhaustive list, or a standard―it’s just my perspective. Use this credo as a starting point for your own compliance credo...