What Darts and professional Compliance Assurance have in common

Have you ever thrown darts on a board? Well, it probably has created some disappointment, targeting the 20 and instead, hitting the 1 or the 5. Similarly, the frustration might be high in Compliance monitoring (1st or 2nd line) when the 25th contract or T&E claim reviewed did not yield any meaningful results and management is bored by your reports.

I’m a passionate hobby Darts player and a Compliance Assurance professional and here are 5 commonalities I see between both.

1) Value

No doubt, this is the most important point and obvious for Darts players. Hit the big triples and go down from 501 to a score that allows you to finish with a double with as few as possible attempts.

For Compliance Assurance it means to focus on those monitoring areas that provide the most valuable insights for the business to enable active risk mitigation and to pick up learning and improvement opportunities. We all know that mistakes happen everywhere and by everybody. But what’s the value of identifying a late contract signature or a slight overspend on hospitality expenditure from a risk and improvement perspective? For the affected individuals it is certainly useful to remind them on the set rules and boundaries but for an organisation/ senior management other areas are more important: How compliant is a new type of business activity executed in practice? Do the controls in the identified high-risk activities work? What can be learned from Assurance observations for control improvements and maybe even for improvements of process efficiencies? If you can answer this type of questions you create real value for the organisation.

2) Attitude

If a Darts player gets distracted or can’t overcome the anger about a previous low score, the performance will ultimately go down. Good players show a very strong mental stability and manage to maintain a high level of relaxed self-confidence even under pressure.

Similarly, it’s important for a Compliance monitor to stay focussed and not to get distracted from side facts or people around explaining that everything is in order. Approaching the monitoring task with curiosity, calmness and self-confidence will always lead to better results.

3) Training

Professional Darts players spend hours in front of the training board. The former 16-times world champion Phil Taylor used to say to his wife that he will only go to bed when he has thrown three 180’s in his last training session of the day. And it’s not only the high scores that Darts players practice regularly. It’s rather a set of skills which also comprises the doubles or different ways to finish.

The importance of training must not be underestimated for Compliance professionals. There is a number of capabilities that are required, many of them being quite dynamic and therefore requiring continuous training such as the awareness of business activities, the knowledge of the external business environment and industry regulations, or the changing risk landscape. For others such as influencing or communication skills, how to execute monitoring activities and develop value-adding recommendations, or how to run internal investigations a mix between upskilling and regular refreshers should be considered. So, as a Compliance professional, there is no need for a training session just before bedtime but make sure there is sufficient space in your busy agenda to develop your skills.

4) Consistency

When you watch Darts players on TV you quickly realise that each player has her/his unique way of holding and throwing the darts, standing in front of the board, or playing with a certain speed. And the speed of throw, the angle of the arm, the position of the feet, where the barrel is held, is applied in a very consistent way.

Consistency is also key for Compliance Assurance. If the monitoring, particularly if performed on a regional level or with global span, is not executed in a standardised and consistent way the results might be misleading and cross-country analysis will be flawed. A few measures can help achieving a better consistency: a) global training programs with practical exercises and participants from different regions on how to execute monitoring, b) a global monitoring guideline that provides practical tips on sample size determination and sample selection, and c) regular sharing of the approach, difficulties experienced, and observations made in the team before consolidating the results.

5) Strategy

For a successful Darts game it is not sufficient to simply throw high value triples. Especially when reaching the finishing zone (170 and below) good darts players follow a strategy how to reach a double they feel most comfortable to hit. And this strategy needs to provide flexibility to account for possible misses on the target field and still be able to finish with three darts. For example, if 72 points are remaining, the player might target the triple 16 to finish with double 12. If she/he only hits the single 16, another 16 leaves double 20.

The key element of a Compliance Assurance strategy is the monitoring plan which usually is created every year. Surely, most organisations have such a plan in place. But how is it developed? This are my tips to improve the value of the monitoring plan:

  1. a) Review the latest risk register and align the plan to the current risk landscape,
  2. b) Review brand plans and other strategic documents of the Commercial unit to identify their priority areas,
  3. c) Capture the input from business stakeholders on what they see as risky areas,
  4. d) Consider a re-assessment of previous high risk activity monitoring to see if learnings and recommendations have been implemented,
  5. e) Define the depth of monitoring by applying a differentiated approach, i.e., using a structured questionnaire to understand risks and controls of new activities vs. transactional testing vs. deep dive,
  6. f) For global organisations, define the global, regional, and local monitoring activities,
  7. g) Build sufficient flexibility in your plan to be able to react on emerging risk activities during the year.  

Impactful communication on the outcome of 2nd line monitoring is not only a key for a successful transformation into learnings and sustainable improvements. It also helps establishing the Compliance function as a valued and trusted partner rather than pointing fingers and blaming people for mistakes and misbehaviour, at least for the more frequent, less serious deviations.

Auditors usually call the detected deviations as findings and there is often no room for discussion.

You may call it semantics, but I strongly believe that FINDING is not the word to be used when Compliance informs about the monitoring outcome. “Finding” has a negative connotation and can be perceived as an irrevocable verdict, not least because people are used to this term from audits.

The term OBSERVATION should be used instead. A monitoring “Observation” shared with the implicated person or the management sounds more neutral, facilitates the discussion about the reason for the mistake, offers the opportunity to clarify facts, and ultimately helps moving Compliance away from the perception of internal police towards a valued and trusted business partner.  

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