other departments to participate in the dialogue--and use the
feedback to help shape further trainings.
Closing
As a seasoned compliance officer, I’ve taken innumerable compliance training courses and exams, and attended countless
panel discussions and conferences. At the highest level, many
sessions usually dive deep into the very serious business of
deconstructing the topic/rule in question. Certainly the doctrinal law is important, as you can’t advise the business if you
don’t understand the rule. But we usually give very little attention to the methods by which we advise the business. We
think of these methods, such as the role playing and interactive
communications approaches mentioned above, as soft skills,
implying that they’re not as important as other skills within
your compliance officer’s toolbox. However, the business won’t
listen to your fabulous advice if they can’t hear it over the noise
of your less-than-artful delivery.
The cherry on the top of your compliance program that make
up the so-called soft skills of compliance are, in my opinion,
just as important as your subject matter knowledge. After all,
anyone can learn a body of law or regulation. What is more
difficult is teaching understanding, empathy, and the impor-
tance of communicating effectively. In addition to learning the
lexicon of their industry and its accompanying regulations,
compliance officers must purposely cultivate strong relation-
ships with their business lines that help ensure the compliance
program is reflective of that collaboration. Be the compliance
officer who promotes a strong culture through communica-
tion. Be the compliance officer who listens. And it might not
hurt to be the compliance officer who stops off at the bakery
on the way to their next meeting. ■
ABOUT THE AUTHOR
BARBARA BOEHLER, J.D., LL.M., is a compliance consultant and
securities subject matter expert at Wolters Kluwer. She is an
attorney and compliance officer with over 16 years of experience
in the financial services sector and has experience developing,
monitoring and assessing both broker-dealer and investment
advisor firms’ ethics and compliance programs. Boehler formerly
served as global chief compliance officer for Arete Research, a
limited-purpose FINRA-registered broker/dealer specializing in
equity research. She also held compliance leadership roles at
Fidelity Investments, JP Morgan Invest, Standish Mellon Asset
Management, and Babson Capital Management. She is currently
a lecturer on compliance-related matters as an adjunct professor
at both the Suffolk University Law School and Suffolk University’s
Sawyer Business School in Boston. She can be reached at barbara.
boehler@wolterskluwer.com.
Endnotes
1 United States Sentencing Commission, Guidelines Manual, §3E1.1, from
Chapter 8.b. 2 (Nov. 2015): http://www.ussc.gov/sites/default/files/pdf/
guidelines-manual/2015/GLMFull.pdf
2 U.S. v. Jacobellis, 1964 U.S. Supreme Court ruling on pornography
definition.
3 Preet Bharara, U.S. attorney for the Southern District of New York.
4 United States Sentencing Commission, Guidelines Manual, §3E1.1, Ch. 8.b. 2
A fundamentally important aspect
in assessing the health of your firm’s
compliance culture lies in evaluating your
compliance team’s soft skills.
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