Did you watch the Madoff mini-series on ABC this week? I recorded it, like I do most TV, and watched the first part last night. There was a scene where Madoff – played by Richard Dreyfuss – comes into an office and says he needs his brother, Peter Madoff, the Chief Compliance Officer’s “rubber stamp” on a form related to an SEC investigation. Yes, in the dramatization, he uses those words.
The interaction was much more blatant than we usually see in compliance, but I think we have all felt that pressure. Someone in a position of power in our organization wants us to sign-off on something that just doesn’t feel right, or on something that merits some looking into but the demand is to “rubber stamp” it now. We wouldn’t be asked to do anything wrong is often the implication and to refuse to sign may be taken as a lack of trust. But it is our jobs in compliance to refuse – to look where no one wants us to look – to take the time to see what is there to be seen.
We know we can’t rubber stamp anything, no matter what the pressure from sales, distribution, owners, etc. We have to look even if there is nothing to see– we are the check and balance in an organization, sometimes the last, sometimes the only.
None of us would have wanted to be Madoff’s CCO. Peter Madoff pled guilty and was sentenced to 10 years in prison. Most of us will never come close to such an extraordinarily criminal operation. Thank goodness, right? But that doesn’t make our role less important. My Friday takeaway is: Keep up the good work – Compliance Matters!