I Came in Like a Wrecking Ball : My Journey Toward Human-Centered and Data-Driven Compliance

I’ve spent most of my career helping companies build, assess, and elevate their compliance programs. Ten years ago, after nearly a decade as a litigator and compliance lawyer, I joined one of the world’s largest biopharmaceutical companies as its lead compliance investigator for the Asia-Pacific region. For nearly three years, I was based in and primarily focused on all things China. And while I could share dozens of surprising, funny, and confusing stories about my life as a fish-out-of-water with the world’s longest commute, here’s one story that really matters: the experience of living and working in Beijing, in one of the most challenging and inherently risky compliance environments you could imagine, began to reshape my view of compliance.

When I arrived in China, I approached compliance with far less nuance than I do today. For one, I was an investigator — and the lines between “right” and “wrong,” “good” and “bad,” “compliant” and “non-compliant” were seemingly well-defined. That’s in large part because the rules were clear — or at least, I thought they were. The messaging was consistent. The effort and investment in compliance was robust. “This is what the Company expects and what law enforcement demands,” I’d think. “So obviously, that’s what people should be doing. And if it’s not working, then we need to do more.” In those early days, I approached compliance like a wrecking ball when what we really needed was a diplomat — or, better yet, a psychologist.