Compliance Thanks in 2018

The day before Thanksgiving is all about slow-rolling your way to early dismissal, so let’s pass the time listing all that we’re thankful for in corporate ethics and compliance this year. I’ll start.

I’m thankful for compliance professionals who update your LinkedIn profiles promptly. You are what makes the Compliance Jobs Report a success.

I’m thankful that the Public Company Accounting Oversight Board finally has a full board again that holds meetings, gives speeches, and otherwise acts the way a regulatory agency should. Now please move your project considering new standards for data analytics in auditing to the top of your priority list.

I’m thankful for the Big Cases Bot, @big_cases, which automatically tweets out links to new filings in all sorts of federal litigation. Such a wonderfully easy way to stay on top of current litigation — especially when the alternative is the PACER system, which I believe was first developed by the Ancient Greeks and is still used by federal courts today.

I’m thankful for good graphic designers, who make the research papers I write so cool and easy to read.

I’m thankful for the misconduct of current and former Trump Administration cabinet members such as Tom Price, Ryan Zinke, and Scott Pruitt; plus staffer Omarosa Manigault-Newman and many others. They provide endless lessons on organizational behavior for the compliance profession.  I look forward to many more lessons in 2019 from acting attorney general Matt Whitaker, commerce secretary Wilbur Ross, and of course President Trump himself.

I’m thankful for the PR people who email me with news, especially when you email me the news with advance notice. I really do read all your emails, even if I don’t reply.

I’m thankful that the Securities and Exchange Commission is pressuring companies to do better at disclosing cybersecurity risks and at managing those risks. Sure it’s a difficult issue, but the SEC needed to address it somehow. The sanctions and guidance the agency has published so far this year are both reasonable, and food for much thought among compliance officers.

I’m thankful for Howard Wilkinson, the whistleblower of the vast money laundering scheme that ran out of Danske Bank for so long. His decision to speak up is bringing all sorts of discomfort to bankers and banking regulators in Europe about their anti-money laundering efforts, and that discomfit is needed.

I’m thankful for PwC’s “State of…” reports: the State of Compliance, the State of Internal Audit, and the annual CEO survey. They always provide interesting reading. (That former PwC guy Lock Nelson and I launched the State of Compliance report back in 2011 has nothing to do with why I still read it, I swear.)

I’m thankful for Bad Banks and Homecoming, two new TV shows I discovered this year where corporate compliance and corporate culture are major themes. They are only two excellent programs in a rich genre.

I’m thankful Amazon decided to put its HQ2 in New York and Washington, rather than Boston, since the proposed Boston location was quite close to my home and we didn’t need that traffic. Then again, I thought all along that HQ2 was really just a scam for Amazon to get promises of tax breaks from local governments across the nation.

I’m thankful that I’m old enough to remember the Red Sox in the 1980s and 90s, when they totally stunk. Puts the World Series victories of this century in proper perspective.

I’m thankful for the new accounting standard for leases, going into effect on Dec. 15. It brings light to off-balance sheet liabilities, which is good for everyone; and provides plenty of fodder for corporate compliance writers and analysts, which is good for me.

I’m thankful for XBRL, the computer language that makes financial data easier to find, read, and analyze. House Republicans tried to repeal the XBRL filing requirement for companies earlier this summer, and that daft idea died a quiet death. XBRL needs improvement, not repeal.

I’m thankful the House also decided not to exempt Section 404(b) of the Sarbanes-Oxley act for a vast swath of public filers. Sure, the SEC will try to expand the exemption on its own in 2019 anyway, but investor and good governance enthusiasts should fight one battle at a time.

I’m thankful that the Society of Corporate Compliance & Ethics will move its annual conference back to the East Coast in 2019 after two years in Las Vegas. Great event as always, but too far for us on the East Coast to fly.

I’m thankful for Roy Snell’s farewell address to the SCCE in October. He gets why we do this stuff.

I’m thankful that Jay Clayton is chairman of the SEC. Even if you disagree with his positions, (which many times I do) he is intelligent, thoughtful, and respectful of others’ viewpoints. The compliance community could do a lot worse with other Trump Administration nominees.

I’m thankful for compliance officers, anti-corruption activists, and business ethics advocates working in places like Russia, China, Nigeria, Venezuela, Saudi Arabia, Brazil. That work is important even when it feels pointless — and it only feels pointless. It is instrumental in the long, arduous, path to better business and better societies.

I’m thankful for all the compliance and audit professionals I meet in this line of work, and for all who have become my friends, colleagues, or just really smart people I know. I’ll talk to any of you, any time. Drop me a line at mkelly@radicalcompliance.com.