Compliance is about culture change, and culture change demands total institutional commitment. For larger business entities, the task is more complex, the stakeholders more diverse and the liabilities usually global in scope. Those who spearhead such change must be transparent in their purpose and resolute in their approach.
As the well-worn cliché has it, “you never get a second chance to make a first impression.” Your words, your deeds, the overall tone you set in the first days and weeks after taking the reins are indeed crucial to your long-term effectiveness, and the successful adoption of your compliance program enhancements. At the same time, a new chief compliance officer (especially one arriving from a different company or a different industry) cannot be presumptuous. Before the CCO talks too determinedly, he or she better know what he or she is talking about.
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