Strategic Compliance: 11 Practical Principles

1. Start by Building Internal Capability—Not by Buying Solutions

Rather than immediately engaging external providers or purchasing software solutions, begin by appointing a senior internal lead, someone directly accountable to the executive team or board. Give this person the space to assess your current position objectively and independently.

This internal anchor ensures:

• Greater control over strategy

• Avoidance of premature investment in unproven tools or large consulting teams

• Stronger alignment with your organisation’s needs and values

2. Stay Realistic—The Threat Landscape Is Evolving

The sophistication of financial crime continues to evolve in tandem with legitimate business innovation. New technologies, decentralised finance, and global networks create fresh vulnerabilities every day.

Assume your knowledge is already outdated unless you’ve made capability development a continuous effort. Cultivate a humble but vigilant mindset—effective oversight today requires constantly refreshed intelligence and adaptive strategies.

3. Budget with Discipline—Results Must Justify Resources

While the scope of financial crime can be large, the solution isn’t unlimited spending. View your compliance and integrity investment as a performance-driven function. Start lean, with clearly defined objectives, and expect early impact.

Initial successes—such as identifying overlooked vulnerabilities or suspicious activities—will justify scaling. Moreover, preserving budget flexibility will be critical should significant incidents emerge that demand financial and operational resources.

4. Elevate the Function—Don’t Hide It in the Org Chart

To be effective, your Anti-Money Laundering (AML) or Anti-Corruption leader must have the authority to challenge across departments and push back when needed. These teams will surface difficult truths and reveal internal blind spots. Position them close to top leadership and reinforce their independence.

Physical and organisational distance weakens their ability to act decisively—especially when pressure mounts.

5. Communicate Openly—Set Expectations Proactively

Prepare your organisation for what you will likely uncover. Adopting a transparent, forward-looking tone builds credibility both internally and externally. State clearly that risks exist, that you are actively addressing them, and that you expect to find issues—because every serious company does.

By owning the narrative early, you:

• Build trust

• Reduce reputational shocks

• Position yourself to credibly communicate progress and resolution later

6. Stay Close—Until Trust Is Earned

In the early stages, keep your compliance and integrity function close—both literally and structurally. Maintain regular oversight and direct communication. This allows you to ensure the function is developing as intended, and not being filtered through layers of optimistic middle management.

When maturity is proven—yes, expansion or decentralisation may follow. But that trust must be earned through performance, not assumptions.

7. Avoid Overreliance on Big Brands

Large consultancies, software vendors, and legal firms have pivoted into compliance advisory—but they’re not always experts in this specific domain. Many are still building their capabilities while selling their services.

Focus on proven expertise, not reputation or branding. And insist on value and results from day one.

8. Be a Fast Follower, Not a Risky Pioneer

Let others take the lead on experimental technologies or inflated compliance programs. Monitor their results, learn from their missteps, and invest only in tested, cost-effective solutions that deliver tangible outcomes.

Behind every failed tech deployment is often a vendor that overpromised and underdelivered. Patience and prudence are advantages in this space.

9. Demand Clarity—Avoid Buzzwords and Slang

If a provider or internal team uses technical language or abbreviations, ask them to explain—clearly and in plain terms. If they can’t, they may not fully understand the topic themselves. Transparency in language reflects clarity in thought.

10. Validate Performance—Don’t Assume Control Exists

If your compliance function cannot demonstrate recent findings or measurable outcomes, you likely have a capability gap. Today, every organisation is targeted, directly or indirectly. A lack of reported issues isn’t a sign of success—it’s a sign that your defences may not be working.

Trust—but verify.

11. Don’t Mistake Silence for Control—Expect Insight, Not Reassurance

A lack of reported incidents does not mean your systems are working. In complex organisations, risk is ever-present. If your compliance or integrity teams consistently report “no issues,” it’s more likely they lack the tools, mandate, or confidence to uncover them.

Don’t reward silence—demand insight. Ask for:

• Patterns of activity

• Near-misses

• External benchmarking

• Detected anomalies—even if low risk

Effective teams surface risk. Ineffective ones claim it doesn’t exist.