Creating A Culture Of Compliance: Fear vs. Love

Dear Import/Export Compliance Manager,

I seem to have a difficult time creating a culture of compliance at my company with regard to import/export.  Our company has an ERP system with a fantastic import/export compliance module bolted onto it so I have the ability to see most of what I need to see and stop what I need to stop.  However, this gives my team and I the same level of popularity as the Ebola virus.  In order to ensure full compliance, do you think it is better to be feared or be loved?

Machiavellian in Memphis

Dear Machiavellian,

The seemingly simple answer is that it is better to be feared.  All import/export compliance personnel need to be feared, in some way, by all company employees, as they are the personnel who can put a major kink in someone’s workload.  Whether it is the engineer trying to get the product designed, the saleslady trying to sneak a product out to Iran, a buyer trying to purchase raw materials from a restricted party or a technician trying to ship a Friday afternoon package without filing out the proper forms, all should know that the all-powerful Import/Export Compliance Department can stop them in their tracks, messing up their timetable and potentially getting them in trouble. 

But is your system full-proof?  What is stopping a chemist from packing up a chemical and shipping it FedEx themselves using the company’s account number?  What is stopping someone from developing a new product and fudging the details in order to avoid the need for export licenses? 

Plus, there are a great many companies, in fact, the majority dealing with import/export compliance, that do not have import/export compliance modules for their ERP systems or even ERP systems at all (hello, Excel spreadsheets!).  For companies like these, with inadequate systems, quite often coupled with inferior, ignored or non-existent processes and quite likely executives that don’t care so much or are ignorant about compliance, fear doesn’t do as much good since you can’t credibly enforce import/export compliance upon people.

Import/export compliance personnel working for companies in this boat must rely more on being loved.  In these settings, personal relationships with logistics personnel, engineers, Sales, Supply Chain and other departments are essential for Import/Export Compliance to avoid being seen as the dreaded ‘Other’.  It is harder for people to scoff ‘Oh, it’s that darn import/export compliance department interfering again’ when they know your kids’ names, what company you used to work for or your favorite local restaurant.  Suddenly, you become a real person who is trying to do a good job, keeping the company out of trouble, instead of the meddler with too much time on their hands.  Chances are, if you’re at this stage, the person has also bought into the message of compliance and what you are trying to accomplish. 

It also helps immensely if you a) show them you understand the basics of their job and how import/export compliance can cramp their style and b) that you are willing to work together with them to create a solution that works for both of you.  An example would be creating a commercial invoice template maximizing the use of autofill and dropdown menus so as to save shipment requestors extra effort typing in the same addresses over and over again (or, worse, causing them to save an old, filled-out copy on their hard drive to reuse). 

Additionally, a major benefit of being loved is that your fellow employees, vendors and other people you interact with are much, much more likely to proactively alert you to something important that you may not be aware of.  In essence, by being loved, you multiply the number of eyes and ears you have out and about noticing things.  As stated before, even the best systems and processes won’t catch everything or, when they do, it may be very late in the process.  You want the shipping clerk to alert you to that one-off, Friday afternoon shipment that may just need an export license.  And you want her to alert you not just because you gave her a gift certificate to the local liquor store in appreciation for the good job she has been doing (though that doesn’t hurt).

Count the Import/Export Compliance Manager as agreeing with Niccolo Machiavelli on this one; it is best to be both feared and loved.