Compliance teams don’t grow in relation to revenue

The Society of Corporate Compliance and Ethics (SCCE) published its Staffing and Budget Benchmarking Guidance Survey 2016. A relevant document for all Compliance Officers and CFOs to compare the own resources to the SCCE’s results.


Buenos Aires

The Latin American Corporate Counsel Association (LACCA) took these statistics and concluded that Compliance teams don’t grow in relation to revenue. This is not an automatic red flag, but has different explanations. It was a pleasure and honor to be involved in this article.

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Compliance and the Ethical Dilemma of Self-Driving Cars

A modern company’s Compliance system works with values and controls, Asimov’s Law provides the basic fixed values for a robot or intelligent software. Similar to a Compliance system we cannot keep the machine alone with this. Artificial Intelligence researcher and author Andrew Rosenblum created the example that the self-driving car faces the situation that a truck is approaching from the front, what surely will destroy the car and kill its passenger. The only possibility to avoid this situation is to swerve and drive the car into a group of 15 pedestrian.  Purely based on Asimov’s Law, the car would have to do the mathematics and decide to sacrifice its own passenger. This may interfere with the car’s obligation to protect its passengers and owner. Due to this, the car manufacturer may feel tempted to include an additional guideline into the software that the car has to protected its owner, as this is the person who pays the company for the intelligent car.

What about the 1:1 situation, where the decision is to sacrifice the passenger or one pedestrian? Here the car has to decide always in favor of its passenger? A government cannot burden such a decision on the car manufacturer, programmer or the software. It is required to establish laws and guidelines, which an Intelligent Software has to follow, especially in such grey areas. If such a near future scenario, the Compliance Officer must be able to control the potential “if-then”-strings of the software, similar as he or she has to control the presented human behavior As the discussion about the Volkswagen defeat-software and emission controls show, software engineers are under high pressure to reach the high external and internal goals; they are tempted to find solutions to bypass the regarding controls.

2010 Alfa Romeo Giulietta

2010 Alfa Romeo Giulietta

Today chip-tuning is already used to change the management of the engine and find additional horse-power. This is in most cases legal, but liberates the car manufacturer from its guarantee. When self-driving cars are a relevant market, it is a question of time, when programmers will offer software to ensure a higher safety for their owners, programmed preference for the passenger against the pedestrians. As different countries have different legal-systems and underlying values, for example Roman or Anglo-Saxon Law. Most properly an auto-pilot requires different processes for such decision making.  In one country choosing the option with the less numbers of victims maybe be adequate, but in another country actively driving the car against this one person may be interpreted as an active killing and murder. Governments and car manufacturers are required to find solutions how to avoid this, via law, but also technical protections against non-approved software. Similar to today’s computer viruses, it will be a continuous competition between new viruses and the anti-virus industry.

Henz, Patrick (2017): “Compliance is a Race Car.”

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Compliance Communication and the sold Painting

Due to the legend, Vincent Van Gogh only sold one painting in his lifetime, the “The Red Vineyard at Arles”, today to be seen at the Pushkin Museum for Fine Arts in Moscow. Other sources doubt this, but it is confirmed that especially in his later years (he came originally from a middle class family) he lived in poverty, as he was not able to create the deserved demand for his art. The critical acknowledgment started only after his death.

In opposite to Van Gogh, the Apple Company is a master in creating successful communication and marketing campaigns. To keep up the hype, the company continuously launches new products, which meet the established high quality level. Communication is important, but it can only work, if the delivered products and solutions can satisfy the promised quality.


2016: Apple Shop, New York

Two relevant examples for the Compliance Officer, as he or she is also a salesperson, selling the Ethics & Compliance message. As Van Gogh shows, it is not enough to have a good product, it must be accompanied by an adequate marketing. The CO not only has to control the company’s gifts & hospitality processes, but further can learn from the sales colleagues.

Every Compliance training is also a sales pitch! It is not enough to only inform the employees, but you have to motivate them. Even the best Compliance controls and processes cannot prevent that intelligent employees could find a way to bypass them. That is why it is imperative that employees do not only comply because they know that there are processes and controls, but because they believe in the sustainable success of clean business. To reach this goal, the tone in the trainings may be different from country to country, but always has to include a certain entertaining factor. This ensures not only that the target group keeps up the attention level, but also humor may inspire to think about the message. Such creativity, of course, requires an adequate and intelligent form of humor, such as irony or sarcasm.

Such communication supports also in another way. As employees talk about the training, the participation rate will go up and the training target gets reached faster.



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Business Philosophy according to Enzo Ferrari: from motorsports to business, Paperback

“An inspiration for managers, leaders and everybody who is interested in Enzo Ferrari’s life.”

Born 1898 in the Northern-Italian city of Modena, Enzo Ferrari lived his dream and founded the world’s most famous sports car manufacturer. This book analyzes how he achieved his goals by what are considered to be modern concepts. Or were leadership theories, emotional intelligence, business ethics, client orientation and sustainability already guiding principles of business in the beginning of the last century.

In his own words, and drawing several parallels to Italian history, he thought he was living in the wrong time. But taking off Il Commendatore’s sunglasses, this book presents him as a surprisingly modern leader, who, conscious or not, acted conform the latest business and leadership models, confirmed by key decisions of his company, including the racing-team.

The book not only uses racing decisions and car development as examples, including many photos, but sets them in relation to Enzo’s personal business philosophy.




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“Compliance is a Race Car.”

Today I finished my essay “Compliance is a Race Car.”, this with the idea to be included into my next book. It started with an idea, but developed in the process. At the end there are many fascinating relations, as both, Compliance Officer and Race Driver, operate in many cases at the limit. Another similarity is that not only the race itself is relevant, but the construction of such a car or Ethics & Compliance program.

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The Compliance Advantage in Mexico, Update

One and a half years ago I had the honor and opportunity to put together a guest blog for Richard Bistrong regarding “The Compliance Advantage in Mexico”. Even if the text was based on the local business philosophy and  not related  to actual developments, now a good time to include some minor updates, as linking the document to the actual statistics and indicators.

Kabah, Mexico

Kabah, Mexico

This changed nothing on the concept; leaving the negative aspects aside for a moment, and turn corruptions risks into compliance opportunities.




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Explaining values & ethics to children: Pepe, The Red Race Car

Value and ethics are learnt in young age by role models as family, teachers or friends. Further, a message gets easier transported via a story. This was the idea to create “Pepe, The Red Race Car”, the fastest one in the early 1950’s and on the best way to win the World Championship. But then his opponent John started to use unfair measures and the deserved title seemed to be out of reach.

As it is important not only to identify injustice, but also to stand up against it, Pepe decided not to give up and to fight for his dream & against the corruption! A fast and entertaining book for children of 6 years and older.

The story is inspired by reality and a good base to discuss values and ethics with children, at home or school.


“4 – 3 – 2 – 1 – Start!” All the cars accelerated with maximum speed into the race. Left, right, right, straight on and left again. Pepe enjoyed it! After half time, he still was on the third position, but could see François and John fighting about the lead. It was a sharp right curve as he saw John breaking late, going alongside the blue car and then boxing him out of the race. Pepe recognized the gray official standing behind the boundary. He must had seen this unfair behavior and disqualify John for that. But to Pepe’s surprise nothing happened. …

Two options are available, book or ebook.



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