Flying a plane is an incredibly complex job that requires tremendous amounts of training. Yet, when a pilot is suddenly unavailable, the airline usually locates another pilot who is equally qualified to fly the plane, and the flight goes off with nothing more than a minor delay.
Is it possible for the same type of seamless transition when the chief compliance officer retires or quits? Or if any key member of our compliance team leaves?
Unfortunately, the answer is far too often “no.” And the reason is that a compliance program is different than a machine, even a very complicated one, that someone can be trained to operate. The pilot doesn’t have to talk to and persuade the plane to fly properly; it responds to the controls and switches that the pilot operates.
