Back in 1977 the first Star Wars the movie hit theaters and took it by storm. It was the start of a global phenomenon. In one of its many key scenes, Han Solo explained to Obi Wan and Luke Skywalker the technical specifications and speed of his Millennium Falcon. Luke had not been convinced to hire Han and his ship, especially as the price for the tour had been quite expensive. For that he supposed only to rent the ship, but not its crew. Han’s simple answer: “But who’s gonna fly it, kid?”
This answer is a good reminder that also the most elaborated Compliance system, with all its processes and tools, only can be as good as the Compliance Officer / Department. Everything depends on the human factor, the Compliance responsible has to be known as a Trusted Adviser in the company and “walk the talk.” But nevertheless he or she is just the enabler; the responsibility for Compliance is with the management. Only if the highest levels of the company live this culture, the employees will follow.
For this it is no surprise that the former U.S. Deputy Attorney General Paul McNulty has another answer for the doubting Luke: “If you think Compliance is expensive, try Non-Compliance.”