Internal Investigations Are a Poe Substitute for Compliance

Happy Halloween! In honor of the holiday, we are taking our compliance message in a bit of a . . . spooky direction. But our message remains the same: International transactions are inherently high-risk; they require constant attention and oversight for your compliance to be effective; and it is always better to put your resources into compliance than to spend them on investigations.

Speaking of Halloween, here are some interesting facts about Edgar Allan Poe:

• Poe ruined a promising start to an army career at West Point by spending his time writing mocking poems about his instructors rather than finishing his assigned work.
• Poe often wrote only after placing a Siamese cat on his shoulder.
• The Baltimore Ravens are the only major sports team to be named after a poem, Poe’s “The Raven.”
• And most importantly, Poe turned down a promising career as a chief compliance officer. Don’t believe me? Check out this recently unearthed initial draft of “The Raven,” and decide for yourself!

Internal Investigations Are a Poe Substitute for Compliance

Once upon a midnight dreary, this Compliance Officer pondered, weak and weary,
Over a list of quaint and curious compliance chores —
While I nodded, nearly napping, suddenly there came a tapping,
As of someone gently rapping, rapping at my chamber door.
“Tis some auditor,” I muttered, “tapping at my chamber door —
Only this and nothing more.”

Ah, distinctly I remember, it was in the bleak December;
When fiscal-year matters come to the fore.
And compliance matters, are quite forgotten,
And talks of investigations, are verboten,
And as welcome as a lingering bedsore,

And yet the knocking — the knocking! — it was far from fleeting.
It thrilled me — it called to me — this was no account-busting lunch meeting!
It filled me with fantastic terrors never felt before.
So that now, to still the beating of my heart, I stood repeating,
“Tis some auditor entreating entrance at my chamber door —
Perhaps some senior officer pleading entrance at my chamber door —
This it is and nothing more.”

Presently my soul grew stronger; had I not mastered SOX? And regs much longer?
“Sir,” said I, “or Madam, truly your forgiveness I implore.
But the fact is I was dreaming, of internal controls, and ethics training,
And so faintly you came tapping, tapping at my chamber door,
That I scarce was sure I heard you” — here I opened wide the door —
Darkness there and nothing more.

Back into the chamber turning, all my soul within me burning,
Soon again I heard a tapping somewhat louder than before.
“Surely,” said I, “surely that is something at my window lattice;
Let me see, then, what threat there is, and this mystery explore —
Let my heart be still a moment and this mystery explore —
’Tis a mistaken Whistleblower and nothing more!”

Open here I flung the shutter, when, with many a flirt and flutter,
In there stepped a stately Raven, a Whistleblower like those of the days of yore.
Not the least obeisance made he; not a minute stopped or stayed he;
But, with mien of lord or lady, perched above my chamber door —
Perched upon a bust of Pallas just above my chamber door —
Perched, and sat, and nothing more.

Then this ebony bird beguiling my sad fancy into smiling,
By the grave and stern decorum of the countenance it wore.
“Though thy crest be shorn and shaven, thou,” I said, “art sure no craven,
Ghastly grim and ancient Whistleblower wandering from the Nightly shore —
Tell me what thy lordly report is from our subsidiaries far off-shore!”
Quoth the Whistleblower Raven: “Your Compliance is Nevermore.”

“Prophet!” said I, “thing of evil! — prophet still, if bird or devil!
By that Heaven that bends above us — by that God we both adore —
Tell this Compliance Officer with sorrow laden if, within our affiliates far offshore,
There are accounting violations or kickback given to dozens or more!
Or payments made to get our products to leave those foreign shores!
Quoth the Whistleblower Raven: “Your Compliance is Nevermore.”

And thus I realized that compliance is toughest when you operate in lands of many scores.
And the Raven, never flitting, still is sitting, still is sitting,
A Whistleblower whose incriminating red flags I ignored,
And his eyes have all the seeming, of an enforcer who is dreaming, of throwing subpoenas on our corporate floor;
And my wretched soul, like our poor compliance, from out that shadow that lies floating on the floor.
Shall be lifted — nevermore!

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