1. Process excellence is key Create repeatable and sustainable processes and be able to demonstrate and document their effectiveness.
2. Strike while the iron is hot Seize this time to bake compliance into the day-to-day operations so that when the pendulum swings the other way, the culture of compliance is engrained into every organization's and executive's DNA.
3. Everyone has compliance accountability Compliance isn't just a department, it is the job of management, each line of business and everyone within an organization. Develop a means to hold everyone accountable.
4. Role clarity is important Be clear on who is responsible, not just the what and the when.
5. Know your escalation route Establish a procedure for vetting compliance issues including whom you will present your recommendations, who the decision makers will be and to whom you will report if decision makers can't agree.
6. Communication leads to clarity Your compliance program must be easily explained to your business partners. Educate and train them to understand the consequences of it not being followed and what is expected of them.
7. Test and retest You need to test your procedures. Don't let the SEC be your first control and monitoring point.
8. Monitor, monitor, monitor Compliance is not stagnant. What works today, even after you test and retest, will not necessarily work tomorrow.
9. Seek outside guidance Sometimes you need outside advice to gain perspective. Take advantage of industry conferences and call friends at other firms. In some cases, you may want to hire a consultant.
10. Be involved Not just within your firm but outside as well. Be a vocal member of a trade association, reach out to regulators and attend conferences.
11. Enjoy your job You can't be effective if you're unhappy. So enjoy what you're doing!