
Safety Net
For so long, I felt like an outsider—the lone compliance voice carrying the weight of keeping everyone on track. But then the big boss pulled me aside and said, ‘You
by Anna Stylianou, Joe Murphy & Jeff Kaplan
In the world of compliance, staying curious is more than just a nice-to-have trait. It’s actually a necessity. Because, as professionals we are deeply involved in the fight against financial crime, our landscape is continually evolving. New scams emerge, regulations shift, and technologies advance at lightning speed.
Curiosity drives us to question the status quo and seek deeper understanding in our daily roles. It encourages us to ask, “Why?” and “What if?” – prompting innovative solutions and new perspectives. This mindset not only helps us adapt to change but also empowers us to anticipate challenges before they arise.
So, let’s embrace curiosity. Let it guide our learning and inspire us to explore new avenues for improvement. In doing so, we not only enhance our own capabilities but also strengthen the integrity of the systems we work to protect.
Wishing you a curious and fulfilling weekend!
Warm regards,
Anna
By Joe Murphy
Anna Stylianou is a leading voice and expert in the global field of compliance in finance. See www.amlcube.com. In her newsletter, AML Weekly Recap and Insights, she recently included this piece quoted above about curiosity.
Over time I have become a big believer in the need for all compliance and ethics professionals to be curious and humble. We should be intensely interested in all parts of the business we deal with, and humble enough to say, “I don’t understand, could you explain that more?” We can never just assume we know or understand something. We always need to keep learning in our work.
As Meric Craig Bloch, a recognized expert in compliance investigations has observed in his writing, this is especially true for anyone who conducts investigations relating to any aspect of compliance. Investigators are not there to “get someone” or prove something. Rather they should be focused on determining the truth, without bias. The best investigators are driven by curiosity – the desire to complete the story and know exactly what happened. This also means the investigator has no reluctance in saying to an interviewee, “I’m sorry, I don’t really understand, could you please go over that slowly for me again?” The investigator may repeat it back to the interviewee just to be sure it is fully understood. Active listening is a core element of this process.
Compliance people deal with all aspects of the business and all kinds of people. We should never assume we know as much as they do, nor be reluctant to learn from them. “I don’t understand, could you explain that to me” should be part of our modus operandi. Every day, every interaction is an opportunity to learn more. This is an exciting part of what we do, and we should view it as part of our profession.
This is not always easy. Picture a meeting of senior people where a highly educated and recognized expert is giving a presentation on technical matters that are essential to the business. There are unknown compliance implications. Everyone else is quietly nodding assent. They might understand this in detail (or maybe they are clueless and quiet, with no idea if the Emperor has clothes or not). You only know that you do not understand. But you are intensely curious and driven to find out what is going on. You may be the only person with the courage to start asking questions, and the humility to say, “I just don’t understand.” You are ready to listen carefully and focus your attention fully, so you can learn all you need to know.
As Anna says in her article: “So, let’s embrace curiosity.” There is so much you can learn by doing this.
By Jeff Kaplan
Learned Hand – considered by many to be the greatest of all US judges – once famously said: “The spirit of liberty is the spirit which is not too sure that it is right.” This is indeed a spirit which sadly seems as distant from us today as it has been before.
Where to start: Humility as a core value
I believe that – at least for some companies – humility should be considered a core value. (I do see this at some companies, but not many.)
Humility is a logical and arguably inevitable response to the vast body of behavioral ethics research showing “we are not as ethical as we think.” Thinking and acting with humility is indeed a way of operationalizing behavioral ethics. (Posts on behavioral ethics are cataloged on my conflict of interest blog: https://conflictofinterestblog.com/2024/01/2024-behavioral-ethics-compliance-index.html )
Humility is also well suited for addressing ethical challenges that are not based on the purposeful failure to be honest but on the less well-appreciated dangers of being careless. Recognizing the limits of one’s abilities – which is part of being humble – should help underscore the need for carefulness.
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