FCPA: Neither snow, nor rain, nor heat…Communicating Your Compliance Story

The Persian Royal Road was built to facilitate rapid communication throughout the Persian Empire. Mounted couriers could travel across the Empire, approximately 1,677 miles; in seven days, the equivalent journey on foot took ninety days. The Greek historian Herodotus wrote of these messengers, “Neither snow, nor rain, nor heat, nor darkness of night prevents these couriers from completing their designated stages with utmost speed” this was later inscribed on the James Farley Post Office in New York and is sometimes thought of as the United States Postal Service Creed.

While communications certainly can be speedier these days, I thought about Herodotus’ quote when I read an article in the Corner Office Section of the Sunday New York Times, entitled “What’s Your Story” Tell It, and You May Win a Prize”. In the article reporter Adam Bryant interviewed Russell Goldsmith, the Chairman and Chief Executive Officer (CEO) of City National Bank in Los Angeles, CA. The article focused on how Goldsmith, who came out of an entertainment industry background, brought the art of storytelling and other techniques which could be used by the compliance practitioner to help employees learn how to do business in an ethical and compliance manner.

Story Idol

City National Bank has a program called ‘Story Idol’. Each quarter the company puts on a competition among its 79 offices. It is designed to create a mechanism “to give colleagues a pat on the back and a moment in the sun for doing the right thing, and it democratizes and decentralizes positive reinforcement.” This is coupled with an annual Story Idol competition in a meeting with the top 300 employees of the company. Employees tell stories “about what they did that promoted teamwork or helped a client by going the extra mile. It’s like telling stories around a campfire, but they’re doing it around conference tables ...

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