Review: The Accidental Compliance Professional

Roy Snell, long-time director of the Society of Corporate Compliance & Ethics who retired last year, has published a book, The Accidental Compliance Professional — one part compendium of advice for fellow compliance officers, one part love-letter to the profession, and all of it bundled with the folksy, friendly tone Snell has been using for years.

Compliance officers new to the profession can read the book ($39.95 for the public; $29.95 for SCCE members) and absorb its lessons, most of which Snell deduced on the fly as he managed university compliance programs in the 1990s. Veteran compliance officers can savor the enthusiasm Snell shows for the profession. He drops names, tells tales, recounts war stories, shares inside jokes.

Readers might recognize some of the events Snell mentions (I remember former FBI director James Comey’s appearance at an SCCE conference in 2014), or even recognize themselves. The book (180 pages) has dozens of photos from Snell’s career at SCCE, with lots of compliance professionals in there somewhere.

Snell organizes Accidental Compliance Professional as a series of 17 lessons for success as a compliance officer. He illuminates those lessons with stories that zigzag between his personal life and professional career — but then, that’s exactly the point. Success at corporate compliance depends on your ability to understand people, and even in the most delicate and complex corporate predicaments, the fundamentals of how to deal with people are pretty much unchanged how you would handle someone at a personal level. Snell understands that truth, and drizzles the point across every page.

Here’s what I like about the book.

It’s well organized and easy to read. Every lesson is short. The language is plain, the examples specific. Within each lesson are “Roy’s Rules” or “Roy-isms” to frame a point in the reader’s head simply; or checklists to help you understand whether you might have a big problem on your hands. A compliance officer can can polish off the whole book in one afternoon.

It’s relatable. Every lesson in the Accidental Compliance Professional includes examples a compliance officer will almost certainly encounter in his or her career. The CEO who likes the idea of compliance program but doesn’t take the training; the mid-level executive under investigation who tries to browbeat the CCO into submission; the low-level executive who wants to obey the rules but is so overwhelmed in daily demands of the job — they’re all in the book.

You know these people. Snell does too. His war stories about dealing with those people are clear, and always connect back to the larger abstract lesson he’s trying to convey.

It captures the central tension of the compliance profession — that this job is about solving problems. There will always be problems. You, the compliance officer, will always have problems of your own, even as you’re trying to build systems and processes to solve the problems of others. By the time you do solve one problem, three more will be knocking on the door.

To that extent, then, a compliance officer should never stress over inadequate resources, people ignoring you, people making mistakes, events moving too slowly for your liking. That’s the job. Only in the rarest of cases (say, when an executive specifically tells you to break the law or lose your job) should you lose sleep at night about working as a compliance officer.

Otherwise, despite everything that goes haywire or the seeming sheer impossibility of the work to be done — corporate ethics & compliance is still a fascinating, challenging field. It’s a field full of people trying to help others be better. No wonder Snell loves the compliance community so much. No wonder he closes his book with this:

“I am too conflicted to assess what I have done, but I know what you have done — of that, I have no doubt. I know for a fact that you have served your country in your own way… thank you for this opportunity to serve as your CEO. Most of all, thank you for your service to me, this organization, and society.”

So, ditto. It’s about people.