Beyond Wishful Thinking: Create a Thriving Culture of Compliance


There’s no question that fostering an ethical compliance culture is a regulatory imperative. Regulators and compliance experts have been talking about it for years. And while terms like culture of compliance and tone from the top are often used in discussion, maybe even to the point of cliché, it remains a real challenge for many firms to apply the concepts in a practical way.

When financial services firms operate under a lax culture the effects can be catastrophic. The Review of the Federal Reserve’s Supervision and Regulation on the Silicon Valley Bank collapse provides insight on how the firm’s culture played a significant role in the bank’s collapse, citing factors including a lack of oversight and accountability by senior leadership, failure to take prompt action when risks were uncovered, and a consensus-driven environment where smoothing over complex issues was the norm.

Just having a Code of Ethics and policies and procedures is not enough. According to the Federal Reserve Bank of New Yorkit takes a rule-obeying culture—a culture of compliance—to make regulations effective. This suggests rules are dependent upon culture, not a substitute for it. Culture provides the shared set of norms that influences employee behavior and decision-making. 

“A culture of compliance embodies a holistic framework within an organization that cultivates a steadfast commitment to upholding legal obligations and regulatory requirements. It fosters an environment where legal norms are deeply ingrained, serving as the bedrock for ethical conduct, risk mitigation, and proactive adherence to the complex web of laws and regulations governing the legal landscape in which the organization operates.”

-Former U.S. Securities and Exchange Commission Director Lori A. Richards

Technology provides a best-practices framework that supports and enhances compliance. Ensuring that employees fulfill their compliance obligations starts with making sure they are fully aware of them. Compliance technology provides a framework for:

  • Analyzing regulatory change to identify the compliance obligations that apply to the firm
  • Identifying policies, procedures and controls that need to be updated
  • Disseminating the appropriate compliance obligations to employees – and making it easy to take the required actions
  • Systematically identifying red flags and concerns


Watch an on-demand MCO webinar on Building a Culture of Compliance


On-Demand Webinar

Beyond Wishful Thinking: How to Create a Thriving Culture of Compliance

Join Michael Rasmussen from GRC 20/20 for a webinar on growing and nurturing your firm’s culture of ethics and compliance. Michael will offer practical guidance on how to improve culture and compliance, including,

  • Driving awareness and understanding of ethical obligations across the organization
  • Developing structure that embeds communication of obligations – and controls for when standards are breached
  • Defining roles and obligations from the C-Suite to the front lines
  • Understanding the importance of policies and procedures

Watch Now!

Related Resources

Download the white paper Conduct and Compliance: A Collective Approach to Ethics and Accountability

Read the blog post A Lack of Compliance Evidence Means It Didn’t Really Happen

Learn about MCO's Know Your Obligations Compliance Oversight Solution