The Integrity Imperative: Rethinking Compliance in an Era of Relentless Change
We live in a time when regulation changes faster than many organizations can track it. Global compliance obligations evolve overnight — sometimes even hourly (or by the minute). Legal frameworks shift, regulators issue new interpretations, enforcement expectations intensify, and risks emerge from every direction: geopolitical instability, AI disruption, ESG pressures, and more. And while the external environment accelerates, organizations are simultaneously changing from within — adapting strategies, evolving processes, onboarding new technologies, growing teams, and expanding their third-party ecosystems.
GRC — governance, risk management, and compliance — as defined by OCEG, is a capability to reliably achieve objectives [GOVERNANCE], address uncertainty [RISK MANAGEMENT], and act with integrity [COMPLIANCE]. Let us focus on that last portion of integrity.
Amid this constant turbulence, organizations face a daunting question:
How do we stay grounded in integrity while everything around us is in flux?
At the heart of that challenge sits the Chief Compliance Officer (or Chief Ethics & Compliance Officer) — or perhaps, more fittingly in this era, the Chief Integrity Officer. I explore this in my blog: There is a new CIO in town . . . the Chief Ethics and Compliance Officer (CECO).
From Compliance to Conscience
The traditional framing of compliance is no longer enough. It has become too reactive, too siloed, too focused on checklists and enforcement rather than empowerment and assurance. Compliance done well is not about playing defense. It’s about leading with values.
If we are to meet the regulatory and ethical demands of the modern enterprise, we must reframe the conversation — from compliance to conscience, from procedural enforcement to organizational integrity.
This is the thesis I bring into my upcoming keynote, “The Integrity Imperative: Ensuring Compliance in an Era of Relentless Change.” We are not just enforcing rules—we are anchoring the organization to its values and obligations, especially when the pressure is highest.
NOTE: compliance and risk management are different functions. In my perspective, in the ideal world (which the real world cannot always be ideal), compliance should never report into risk management (and it should not report into legal). I discussed this in my blog: Risk Management vs. Compliance Management: Understanding the Distinction.
The Role of Culture: A Unified Compliance Ethos
Compliance is not merely a function of having the right technology or a well-staffed compliance department. It depends on culture. That was the focus of the afternoon panel I joined at the Summit: “What Does a Unified Compliance Culture Look Like?”
The reality is this: compliance without culture is fragile. A culture of integrity, on the other hand, embeds ethical behavior across all the organization.
Yet, many organizations suffer from:
- Communication breakdowns between compliance and operations
- Inconsistent ownership of compliance obligations
- A view of compliance as “someone else’s job”
- Minimal engagement from leadership beyond formal attestations
To build resilience, organizations must elevate compliance as a shared responsibility—integrated into decision-making, performance management, third-party relationships, and strategic planning.
Reimagining the Chief Compliance Officer as the Chief Integrity Officer
Let’s talk about leadership.
In a world where ethical missteps can go viral, and regulators expect organizations to demonstrate intent and accountability, the role of the Chief Compliance Officer is evolving.
I propose a shift in mindset: from Chief Compliance Officer to Chief Integrity Officer.
Why? Because this role is no longer about merely ensuring regulatory adherence—it’s about embedding a culture of accountability, transparency, and trust. It’s about serving as the conscience of the enterprise—an enabler of values, not just an enforcer of rules.
The Chief Integrity Officer:
- Connects corporate purpose with operational behaviors
- Bridges legal obligations with ethical decision-making
- Leads proactive governance of AI, ESG, and third-party risk
- Ensures regulatory change is translated into action across functions
- Builds trust with regulators, investors, and the public by demonstrating alignment between words and actions
The Mounting Pressures of Regulatory Change Management
In my current three-week tour through Europe, I’ve seen first-hand how the regulatory change agenda is dominating boardroom and C-suite conversations. Across London, Copenhagen, Barcelona, Madrid, and Zurich, Regulatory Change Management (RCM) has come up in many conversations I’ve had (going through my notes, over 30). At the Global RegTech Summit in London, I moderated a main stage panel titled “RCM Reimagined,” and the questions from the audience were sharp and urgent:
- As AI and automation become foundational in RCM, how do we ensure accountability and compliance when machines make decisions?
- How can mid-sized firms adopt sophisticated RCM tools without enterprise-scale budgets?
- What happens when regulatory expectations conflict across jurisdictions?
Organizations are overwhelmed—not just by the volume of regulatory change, but by the complexity of interpreting, implementing, and operationalizing it. In my Zurich workshop hosted by Corlytics, we cataloged over 20 recurring pain points, including:
- The pace and volume of change
- Shadow AI and ungoverned tools interpreting regulatory data
- Data quality and legal accountability
- Siloed compliance teams and disjointed internal communication
- The struggle to keep policies and controls aligned with evolving rules
- And critically, interpreting what is material and relevant to the business context
This is not sustainable with spreadsheets, email chains, and reactive workflows.
Blueprint for Modern Compliance: From Theory to Execution
In my upcoming London workshop, “Compliance & Ethics Management by Design,” I’ll be helping attendees build the frameworks needed to operationalize this vision. We will dive into how to:
1. Build Governance Structures for Compliance
- Create a Compliance Governance Committee that integrates diverse roles
- Draft a Compliance Management Charter that defines structure and scope
- Develop a strategic plan aligned with board-level goals and objectives
2. Design the Compliance Lifecycle
- Map and monitor compliance obligations
- Establish communications, attestations, and engagement
- Assess controls and effectiveness
- Integrate compliance with third-party risk oversight
- Align metrics, reporting, and assurance
3. Architect the Right Technology
- Understand the types of compliance information and workflows
- Define requirements for a compliance information architecture
- Evaluate platform capabilities that support AI-assisted compliance, monitoring, and performance tracking
- Develop a compelling business case for investment in compliance modernization
Closing Reflections: Lead with Integrity, Not Just Compliance
We are NOT here to check boxes.
We are here to build organizations that do the right thing, even when no one is watching—organizations that can stand firm in the face of scrutiny because they are grounded in purpose, values, and trust. In the words of my favorite fictional Premier League coach and philosopher, Ted Lasso, “doing the right thing is never the wrong thing.”
In this era of relentless change, the most valuable compliance strategy is integrity by design.
Let’s stop managing compliance in silos and start leading with conscience.
Let’s reframe the conversation—because risk is our business, and integrity is our foundation that allows us to achieve what OCEG calls Principled Performance . . .