So, a lot of readers — well, a couple of people . . . okay, one person, and it might have been my mom — have asked for a third Christmas compliance parody article. And since we are nothing but compliant (sorry, we couldn’t resist), we have taken up the challenge! But to start things off, here are a few fun facts about the most famous American poem of all time:
- “‘Twas the Night Before Christmas” was written by Clement Mark Moore, a professor of Theology and Oriental and Greek Literature, who wrote it for his children while riding in a Christmas sleigh. A visiting friend was so impressed that she sent it to a newspaper editor (without permission), who began an annual tradition of publishing it.
- The poem established many Santa attributes that survive to this day, including the red suit, the bundle of toys, the eight flying reindeer (and their names) pulling a sleigh, filling stockings with gifts, the smoking pipe, and entering the house through the chimney.
- The reindeer “Donner” and “Blitzen” were originally named “Dunder” and “Blixem,” which were plays on “Donder” and “Blitzen,” Dutch words for “thunder” and “lightning.”
- An original copy of the poem Moore wrote and signed for an acquaintance in 1860 sold for $280,000 to a Manhattan CEO, who wanted to read it to his guests (in a protective plastic sleeve) at his holiday party.
- But the joke is on the CEO, because we have unearthed the real, original version of the poem, which actually was a compliance tutorial! We have reviewed it carefully and find that its compliance suggestions still resonate today. So as a service, we herein are reprinting …
“‘Twas the Night of Compliance”
‘Twas the night of compliance, or so it was thought,
But the program was missing, the rules overwrought.
The policies? Nonexistent. The training? A joke.
And this CCO sat there, beginning to choke.
My staff were all swamped, with deadlines to meet,
While whistleblowers whispered of lies and deceit.
And I at my laptop, my head in my hand,
Knew compliance tonight would not go as planned.
When out of my inbox, there came such a fright,
A flood of new cases, at the stroke of midnight!
To my Compliance Dashboard, I flew in a flash,
Dreading the data breach or theft of our cash.
The reports trickled in, oh, what a sight,
Red flags were flashing through the whole night!
When, what to my bloodshot eyes should appear,
But a mountain of audits — all urgent and clear.
My staff all panicked, the accountants were pale,
Our company lost track of standards, and everything failed.
And what to our wondering eyes did appear,
But stacks of violations — it was worse than we feared!
More rapid than audits, the problems they came,
This CCO trembled, and called them by name:
“Now Misconduct! Now Fraud! Now Sanctions and Fines!
“On GDPR! On SOX! All on our Hotline!”
I instructed my staff, “read every part of the file!
Now audit! Now investigate! This could take a while!”
Without any guidance, no rules to enforce,
The company was spiraling far off its course.
The culture was broken, the ethics undone,
And this CCO wondered, “How did this all come?”
And then, in a heartbeat, I heard a soft ping,
A hotline alert that made my nerves sting.
As I opened the message and scrolled through the case,
Another compliance disaster was now taking place.
It was fraud this time, with fines on the brink,
I sighed in defeat, pouring more coffee to drink.
A bundle of reports, all piled in a stack,
And I knew right away, there’d be no turning back.
The hotline kept ringing, the claims didn’t slow,
While investigations came down like thick falling snow.
Another breach here, a violation there,
The weight of compliance was too much to bear.
Without regulations, the company was weak,
No oversight, no checks, a stunning critique.
This CCO sighed, the weight felt immense,
A company in freefall from lack of defense.
But then, as I sat in the midst of the storm,
A thought slowly took on a new form.
What if this chaos, this never-ending mess,
Wasn’t from bad luck, but from lack of finesse?
There was no risk assessment, no program in place,
Just a mad rush to sell at a frantic pace.
Each crisis that came, we scrambled to fix,
But nothing strategic, no preventive tricks.
This CCO blinked, and said with a start,
“A well-structured program — that’s where we’ll all start!
No more reacting to every new fright,
A compliance framework can make this all right!”
I sprang to my feet, determination aglow,
“I’ll build us a system, our compliance must grow!
A risk-based approach, that’s where we’ll begin,
With proactive measures, we’re all sure to win!”
With a plan in my mind, and hope in my heart,
This CCO knew compliance would soon play its part.
For without good compliance, chaos would reign,
But a structured program would ease all the strain!
And I heard myself declare, as I drafted that night,
“A good risk assessment will keep things airtight!
No more disarray, no more compliance blight,
We’ll comply the best way — and manage risk right!”
Looking for more articles on the lighter side of compliance? Try out There Must Be Fifty Ways to Leave Your Agent, Internal Investigations Are a Poe Substitute for Compliance, The Grinch Who Stole Compliance, Peter Rabbit Discovers Compliance!, The Missing Sound of Compliance, and The Compliance Mash! If you would like to see future updates regarding “What Every Multinational Company Needs to Know” about operating in today’s complicated international trade world, please sign up for our biweekly email list. Click here to register.
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