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Alexandra Wrage
President and Founder, TRACE

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Nicola Bonucci 
International Lawyer and former
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Dave Lee
FCPA Compliance Consultant, TRACE
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Sunny McCall
Senior Director II, Compliance Training, TRACE
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Lee Nelson
Independent Compliance and
Ethics Attorney
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Jessica Tillipman
Associate Dean for Government Procurement Law, The GW University Law School
  • Writer's pictureLee Nelson

Dollars & Sense: Requesting an Increase in Compliance Resources

reviewing graphs

‘You get what you pay for’ applies even to compliance programs. Compliance leaders with stagnant or shrinking budgets cannot lead with that commonsense adage, however, and instead must methodically confront management’s calculation – some call it fantasy – that existing human and technical resources can simply be re-balanced to handle ever-expanding risks and the resulting increased workload. Ironically, that sort of math is yet another risk to deal with.


Here’s how. Requesting additional compliance resources will require grit, your sales hat, and a thoughtful presentation. While you are preparing that, block time on key stakeholders’ calendars well in advance of the budgeting cycle so that any thought seeds you can sow will have time to grow, perhaps even bloom. Regarding the presentation:


  1. Start by stressing that the compliance program is mission critical, and its objectives support the organizational wider goals.

  2. Provide details on the types of risk compliance manages globally and explain how those are increasing in complexity and volume, including new laws and regulations on the horizon.

  3. Spotlight the potential impact to brand, reputation, and the cost for failing to comply. Examples that include actual settlements and penalties paid, especially from your industry and competitors, will get the most attention. Also estimate the cost to hire outside counsel and other professionals who would conduct an investigation or defend against allegations.

  4. Show the current state of your program by mapping the various risks to your existing resources and explain how systems support the team’s efforts. If possible, benchmark your organization's compliance budget to industry peers or organizations of a similar size, especially if your budget is below the average.

  5. Identify gaps in coverage and show how additional funding would enhance compliance efforts to fill those. Examples help. Explain hypothetical downside scenarios of what could go wrong if X were to occur in Y country and the consequences. Finish each example by juxtaposing the cost of the requested resource against the eye-popping size of potential penalties, including outside counsel and other professional fees. It also helps to stress a couple of upsides - the ones the team caught and averted – to emphasize the program’s effectiveness.


There – you have tactically supported your request with facts, data, scenarios, sincerity, and wit. Ideally, you also will have made progress toward the strategic goal of convincing management that the compliance program is an investment that provides real and measurable ROI (return on investment) and supports the organization’s principles. That sort of math computes!



Independent Compliance and Ethics Attorney

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