01 // TELL US WHAT YOUR GROUP IS FOCUSED ON THESE DAYS.
Our focus is on anti-money laundering, data protection and the Foreign Corrupt Practices Act.
02 // WHAT SPECIFIC INITIATIVES HAVE WORKED WELL THAT YOU CAN SHARE WITH OTHERS?
One of our key initiatives is to ensure that there’s execution and implementation of compliance initiatives. Putting in place robust monitoring, metrics, six sigma and project management rigor through training and mindset are all ways to ensure execution rigor.
03 // ARE THERE ANY PARTICULAR TOOLS YOU USE TO GET THAT MESSAGE TO THE GROUND FLOOR?
Yes, the Compliance and Control ratings process. At the beginning of the year the business leader in business units around the world sits down with their compliance leader and identifies specific action items in the compliance area which must be achieved that year. At midyear there’s a touch base, and at the end of the year there’s a final assessment. The result is then scored and the score affects the bonus pool for the employees in that business unit. Tying compliance performance explicitly to pay is a key measure for encouraging cross-functional and business leadership ownership of compliance.
04 // WHAT PART OF YOUR BACKGROUND HAS MOST PREPARED YOU FOR THIS POSITION?
The things that former Defense Secretary Rumsfeld called “unknown unknowns”- things we don’t know that we don’t know. The best in-house counsel and compliance officers anticipate what’s around the next corner, and are extremely proactive on the cost and risk management fronts. It’s not easy, but it’s essential to aligning objectives with the business and sustaining high performance.
05 // WHAT KEEPS YOU UP AT NIGHT?
Knowing that no matter what systems and processes you put in place, a single slip up anywhere in the world can have a legal or reputational impact on the company.
06 // IS THERE ONE SPECIFIC PIECE OF ADVICE THAT YOU COULD SHARE THAT YOU WISHED YOU HAD KNOWN WHEN YOU FIRST GOT THE JOB?
Ensure that you spend the majority of your time understanding your team and the people and environments in which you work. For a compliance leader it’s a matter of knowing how to leverage the team and work with the business to drive change in a way that’s owned by and integrated with the business’s goals.
07 // WHO DO YOU REPORT TO? WHAT ROLE HAVE THEY PLAYED IN THE COMPLIANCE AND ETHICS PROGRAM?
I report to Tim Heine, Managing Counsel for American Express. Tim has been enormously supportive and in fact he’s the best manager I’ve ever had in 23 years of being a lawyer. He provides counsel, advises me on the landscape that I’m working within and supports me in resource requests and other needs within a large organization. His counsel is especially valuable given that I’ve been at the company for less than a year.
08 // WHAT MAKES AMERICAN EXPRESS COMPLIANCE A GOOD PLACE TO WORK?
Number one, the tone from the top is unparalleled in my experience. The CEO, board of directors and top management are supremely supportive of compliance; setting out for ourselves the goal of producing an industry-leading “best in class” compliance program; agreeing to provide resources; clear messaging to the business leadership; investing in infrastructure and spending their own personal “share of mind” on compliance.
