Especially in the phase of a first implementation, a Compliance department may be referred to as the “dark side”. At first, this in relation to the Star Wars-movies, and the picture of Darth Vader comes in mind, who tries to convince his son Luke Skywalker to join the Empire, so that both of them could rule the galaxy together.

But if you continue thinking about it, it reminds more to the dark grey world of the Czech author Franz Kafka. If a company is implementing the Compliance system as result of an actual corruption case and under time pressure, the focus will be on “detection” and “response” rather than on “prevention”. For a limited time, a rules based corporate culture is required. The relation between rules & values is outside its natural equilibrium. It has a kind of irony that a company or other organization needs to ensure transparency with implementing bureaucracy.


If the rules are established, the emphasis has to switch as soon as possible on values and attitudes, as a pure “check-the-box”-Compliance system is not sustainable and will sooner or later cause new violations, as employees perceive their-selves inside faceless processes, where at the end unknown headquarter managers decide about their requests and behavior.

As guidelines cannot define all aspects of business life, violations to external laws will happen sooner than later. Due to this, modern Compliance systems are based on controls and values, where both are inside the equilibrium. Depending on the organization this can be in the middle or a little bit more on values or a little bit more on controls.