In this episode, I consider Conan Doyle’s third Sherlock Homes novel, The Hound of the Baskervilles. The novel, originally serialized in The Strandfrom 1901 to 1902, is generally recognized by Sherlockians as the premier Doyle work regarding his fictional detective. I use this novel to illustrate how you can plan out and schedule 90 days to innovation for your compliance function.
Doyle’s idea for the story derived from the legend of Richard Cabell, which was a tale of a hellish hound and a cursed country squire. Squire Cabell was a hunting man and who was described as a “monstrously evil man”. He had a reputation “for, amongst other things, immorality and having sold his soul to the Devil. He was also alleged to have murdered his wife. As the story goes, Cabell was laid to rest in ‘the sepulchre’, but night of his interment saw a phantom pack of hounds come baying across the moor to howl at his tomb. From that night onwards, he could be found leading the phantom pack across the moor, usually on the anniversary of his death. If the pack were not out hunting, they could be found ranging around his grave howling and shrieking. In an attempt to lay the soul to rest, the villagers built a large building around the tomb, and to be doubly sure a huge slab was placed. To add good measure, the folklore of the county where the tale occurs, Devon, includes tales of a fearsome supernatural dog known as the Yeth hound.”
The Hound of the Baskervilleswas a tale that appeared to have supernatural implications. Yet, upon closer examination, a more temporal solution was determined. I thought of this novel when reading the article entitled “Build an Innovation Engine in 90 Days” by Scott D. Anthony, David S. Duncan and Pontus M. A. Siren in Harvard Business Review.
The authors recognize that innovative ideas get brought to the marketplace often through “individual heroism and a heavy dose of serendipity” but companies need a mechanism to “make the process more reliable and repeatable without making major organizational changes.” To do so, they suggested a solution they call the “minimum viable innovation system” which can bring an innovation to fruition within 90 days. I have adapted their system for the compliance function.
Day 1 To 30 - Define Your Innovation Buckets
Innovations can either be inward or outward facing. This is also true in the compliance function as your compliance program relates to your own internal clients, customers and your third parties. It all begins with two steps (1) Determine between compliance goals and current operations; and (2) determine broad categories of compliance solutions which could fill that gap. If your gap is large, you might sub-divide your compliance efforts so that “you can map them to different directions for future [compliance] growth. You should not take on more than three as an initial effort.
Day 20 To 50 - Zero in on a Few Strategic Opportunity Areas
You need to meet with your customer base to “probe unmet needs”. You can use town meetings, compliance focus groups or meetings with individual employees. Also look outside your company by engaging in benchmarking through investigation on new developments in your industry and in the compliance space. This is also a time when you can best use big data through a data analytic approach to spots trends in your organization that might present opportunities for compliance innovation.
Day 20 To 70 - Form a Small Dedicated Team to Develop the Innovations
In three steps you should accomplish the following. First, dedicate a handful of the company to developing the compliance innovations. Second, work with the Chief Executive Officer and Chief Financial Officer to eliminate “zombie” compliance projects. Third is to develop a process checklist.
Day 45 To 90 - Create a Mechanism to Shepherd Projects
During this time frame, the authors suggest two major goals for oversight. First is that the CCO needs to select and train compliance leaders to oversee the innovation team and to establish oversight rules. The group of compliance leaders who will have the autonomy to make decisions about starting, stopping, or redirecting compliance innovation projects. You should take care not to simply replicate the current executive committee, because if you do, it will be too easy for group members to default to their corporate-planning mindset or to let day-to-day business creep into discussions about compliance innovations meant to fulfill long-term goals.
The authors’ formulation is an excellent way for a CCO or compliance practitioner to think through the process to design and create innovation in your compliance function. Just as Holmes methodically worked through the clues in front of him (and some behind him) in the The Hound of the Baskervillesyou can use this protocol to assist you moving forward.
If you are looking for the top compliance training class around, the Compliance Master Class. If you would like information please email at tfox@tfoxlaw.comand I can forward you the agenda. If you would to register, you can do so here.