Kristy Grant-Hart (kristygh@sparkcompliance.com) is the Managing Director of Spark Compliance Consulting in London, and author of the book, How to be a Wildly Effective Compliance Officer.
Sometimes, no matter what you do or how persuasively you try, the answer is simply no. Perhaps you know that the company’s current due diligence process is deeply underfunded and therefore is not picking up risks that should be caught. Perhaps you’ve tried to convince the board that they should invest in measures so that the company can be compliant with the new European General Data Protection Regulation. Perhaps you’ve written three reports detailing the need for sanctions-screening software, but you are still left with an Excel spreadsheet and no capacity to reliably screen for customers that might be sanctioned bodies. When this happens, try these three reactions:
