Another reason I moved to Saudi Arabia is that I want to be a part of history in the making. I witnessed the positive transformation in South Africa at the end of apartheid, and I am now witnessing another major transformation in Saudi Arabia related to gender reforms.

Women play a vital role in Saudi Arabia’s Vision 2030 strategy, an ambitious plan to diversify the country’s economy from oil independence. These gender reforms have had a remarkable impact on the country and the livelihoods of many families. The number of females breaking the glass ceiling is inspirational. One of the country’s first astronauts to the International Space Station was a woman, Rayyannah Barnawi, as is the Saudi ambassador to the United States, Ambassador Reema bint Bandar Al Saud. These developments are significant because they show that Saudi Arabia is committed to empowering women and giving them opportunities that were previously unavailable.

I must give credit to my Saudi colleagues—both male and female—who have shattered my preconceived notions about women in this region. The Saudi women in my acquaintance have impressed me by their intellect, drive, assertiveness, and sense of humor.

AT: To me, your career shows that the compliance profession is in demand everywhere and has enormous opportunities. Would you agree, or am I viewing things too optimistically?

FM: I first encountered compliance as a career in 2007, when PwC seconded me to assist Siemens with their anti-corruption remediation program. As a South African lawyer with expertise in anti-corruption and the Foreign Corrupt Practices Act, I was tasked with leading a working group in Germany. The group consisted of Siemens employees and PwC consultants from all over the world, with both legal and nonlegal backgrounds. This experience showed me that there are opportunities for compliance professionals at a global level, regardless of nationality or qualification.

I have been working in compliance for 16 years and have seen the profession grow significantly in that time. This is due in part to increased regulatory scrutiny, financial crime enforcement, and regulatory requirements in countries such as the United Kingdom, France, Spain, and Brazil, to name a few. The growing demand for compliance professionals reflects the need for organizations to have the expertise and resources to navigate the complex and ever-changing compliance landscape. The demand for compliance professionals is high in all industries, countries, and levels of seniority. I have seen this firsthand in my career.

AT: What skills and qualifications helped you get to where you are?

FM: I was not familiar with compliance when I started my career, as was the case for many of my colleagues. I remember meeting Roy Snell, the former CEO of SCCE & HCCA, at a conference in Milan a few years ago. We discussed how we both “accidentally” fell into compliance roles with no training or prior experience. He wrote about this in his book, The Accidental Compliance Professional, which I highly recommend.^[1]

I learned most of what I know about compliance through my work experience. My time on the Siemens project—where I learned how to create a best-in-class compliance program—was a major turning point in my career. I was able to leverage what I learned from this project to help design and implement compliance programs in subsequent in-house roles.

While a legal background is not required for a career in compliance, I believe that getting certified in compliance is a valuable step. The Certified Compliance & Ethics Professional – International (CCEP-I) certification is a particularly good option, as it provides a solid foundation for understanding how to build effective compliance programs. I believe that it is the best compliance resource available.

AT: You switched your career from a lawyer to a forensic accountant and are now a compliance officer. What attracted you to the field of compliance, and was it an easy transition?

FM: I am driven by the desire to “fix” things, which is why I am passionate about a career in compliance. I am drawn to companies that are in need of compliance assistance. I enjoy helping them to navigate complex regulatory environments and to remediate any issues they may have. I have also left companies where I was not making an impact, and where compliance was seen as a tick-box exercise.

The transition from lawyer to where I am now has been easy, as these careers complement each other. My career as a lawyer and forensic accountant has given me a unique perspective on compliance risks. My legal training gave me a deep understanding of the laws and regulations that apply to organizations, and my experience as a forensic accountant showed me how corruption, fraud, and other financial crimes can occur.

On the other hand, the transition from being a consultant to an in-house compliance officer was not as easy. I had to unlearn many habits that were not conducive to my new role, such as drafting concise and persuasive communications and learning how to work with the business. As a consultant, I could simply provide my recommendations and leave; however, as an in-house compliance officer, I need to find solutions that work for the business and, at the same time, mitigate compliance risks. One thing I definitely do not miss is completing timesheets!

AT: What do you find is the key to navigating across cultures on a person-to-person level as you move around the world?

FM: Navigating across cultures can be challenging, but it can also be incredibly rewarding. Here are some tips that have helped me.

Be respectful, open-minded, and mindful of other cultures, customs, beliefs, and values. This means being aware of the nuances in each culture, such as the fact that it is a cardinal sin to visit someone at dinner time in the Netherlands, but strangers will be honored to invite you home for dinner in Saudi Arabia. In the Netherlands, going “Dutch” is expected; in Saudi Arabia, I have had physical altercations trying to pay the bill.

Integrate with residents and learn the local language. This will help you communicate with the locals and will also make you a source of comic relief, as you will inevitably make mistakes. For example, in Tanzania I used to bid farewell to my driver in Swahili, but I was unknowingly making a much bigger commitment. I thought I was saying, “I will see you tomorrow,” but I was actually saying, “I will marry you tomorrow!”

Be patient, flexible, and able to adapt to new ways of doing things. This is essential, as you will inevitably encounter situations that are unfamiliar to you.

Be authentic. Having a genuine interest in people will make you more approachable and help you build meaningful relationships.

I have learned a great deal about diverse cultures and about myself, as these experiences have, I believe, made me a more well-rounded and tolerant person.

AT: What about as a compliance officer? Is it any different to connect with businesspeople in one culture or another? 

FM: Most of the behaviors described above have helped me build a rapport with my colleagues around the world.

As a compliance officer, it is important to be mindful of the different ways that people communicate, interact, and behave. This means being clear and concise in your communication and being aware of cultural sensitivities.

I have learned that my dry sense of humor does not always translate to other cultures.

Also, learning about customs, cultures, and sensitivities before traveling to that country is important in building connections with people who have different mindsets. I learned an expensive lesson when I visited Morocco. I presented a Transparency International world map that showed the border of Western Sahara. Morocco does not recognize this border, which resulted in my entire presentation being derailed. I was lucky not to have been deported!

AT: You worked as a chief compliance officer for Maersk, which has a diverse workforce from around the world. How do you bridge significant cultural gaps to build a common compliance culture?

FM: I faced this challenge not only at Maersk but also at other multinational companies that had global operations. To embed a compliance culture in many dissimilar locations, it is essential to have local and/or regional teams who are on the ground, speak the language, and understand the culture. Additionally, appointing compliance champions in entities facing high compliance risks will help embed the compliance footprint.

Regional teams can provide insights into the local culture and ensure compliance policies and procedures are adapted to the local context. Compliance champions, on the other hand, are responsible for raising awareness of compliance issues and promoting a culture of compliance within their respective entities. The compliance champion program at Maersk was sponsored by the CEO and was an integral part of implementing the compliance program.^[2]

AT: You have had senior roles in both the shipping and construction industries operating in countries that attract enormous anti-corruption risks. What do you think makes for a successful compliance effort in this extremely difficult area?

FM: The foundation of a successful compliance program starts with an effective risk assessment. This includes identifying both internal and external risks, as well as the likelihood and severity of those risks. To create your inherent risk scores pertaining to anti-corruption, I suggest risk rating these factors at a minimum: the location of its operations; the industry sector; business partners; transactions with foreign governments; payments to foreign officials; use of third parties; gifts, travel, and entertainment expenses; and charitable and political donations.

Risks are not the same in each company or industry and need to be mitigated by tailoring your program. The construction industry could, for example, face requests for bribes or facilitation payments with respect to building or environmental permits, whereas the shipping industry could face requests for facilitation payments from pilots to navigate their ships.

I am proud of Maersk’s leadership in the fight against corruption in the maritime industry. Maersk was one of the founding members of the Maritime Anti-Corruption Network (MACN), which has become one of the most effective collective action groups globally in reducing and eliminating facilitation payments.^[3]

Before these measures were implemented in the Suez Canal, it was known as the “Marlboro Canal” because facilitation payments to pilots were made in the form of cigarettes.^[4] MACN and its members have made inroads in helping to change this culture and make the Suez Canal a more transparent and compliant place.

AT: How do you make the compliance program relevant to a workforce ranging from executives in office towers to sailors far out at sea?

FM: Not all employees will be exposed to the same risks, so the compliance program should be tailored to the specific roles and responsibilities of each employee. For example, executives may need to receive in-person training on the company’s anti-corruption policies, while sailors will receive tools to teach them how to stand their ground when faced with a request to pay a facilitation payment.

There are some elements that will be applicable to all employees, one being the ability to report misconduct or compliance violations without fear of retaliation. A reporting mechanism that is easy to use, trusted, and confidential is essential for all employees to feel comfortable reporting misconduct or compliance violations, regardless of their role or location.

AT:You have experience in managing risks in both mature organizations and relatively new ones. Are there any similarities or differences in how risks are managed in these two distinct types of organizations?

FM: While mature organizations typically have a well-established compliance program in place, some may only invest in improving it when they are facing regulatory scrutiny or required to do so by law. Startups, on the other hand, typically prioritize their investments on research and development, sales, and marketing, and getting up and running. They may not necessarily focus on compliance programs or ESG frameworks at the outset. However, I would encourage startups to design and implement a compliance program, as it allows them to start with a clean slate and avoid being bound by legacy or outdated controls.

Whether in a mature organization or a startup, the starting point for designing any compliance program is to understand the compliance universe and identify and assess the risks the organization is exposed to. This involves understanding the company’s business activities, the regulatory environment, and the potential consequences of noncompliance. Compliance should be an integral part of the organization’s overall risk management strategy.

As the startup evolves, the risks will change, which means that the program must also be agile and scalable so that it can grow as the organization grows.

AT: What have you found to be the best reporting structure for the compliance function? I would imagine you would need to be very close to leadership to be effective.

FM: It depends. The reporting structure of the compliance function has varied from organization to organization. In some cases, it reports to the legal department, while in others it reports to the governance, risk, and compliance (GRC) or risk functions. The success of the compliance function depends on its support and visibility from senior management and the board. Reporting directly to the CEO and the audit, risk, and compliance committee is best practice. This ensures that the compliance function is integrated with the company's overall strategy, has the buy-in of senior management, and is able to promote an active culture of integrity from the top.

AT: Given that you are so deeply involved in an organization committed to creating the future, how do you see the future of compliance? How do you anticipate evolving over the next five years?

FM: Compliance programs are evolving to address new challenges in the digital age, such as digital compliance, data privacy, and cybersecurity. These challenges are especially prominent in the context of artificial intelligence. Compliance programs are also evolving beyond anti-corruption to include other principles of ESG.

The era of check-the-box compliance is over. Instead, compliance professionals are increasingly using behavioral science to design and implement compliance programs that are effective in changing behavior.

AT: Do you have any advice for compliance professionals considering a position in the Gulf region? Many people are more than a bit intimidated, and yet I have consistently found the people there to be incredibly warm and welcoming.

FM: If you want a challenge and want to make a difference, I urge compliance professionals to consider a career here. Nonfinancial services compliance is gaining traction in this region, and there are many opportunities to help grow the compliance field here.

I advise discerning what you read and hear in the media, as it often does not reflect the reality of what is happening on the ground. I would encourage you to visit the country and interact with the people firsthand to see how they are working to make this region a more inclusive and progressive society and experience the warmth, generosity, and hospitality for which they are known.

I am cognizant of the challenges that Saudi Arabia faces, and while a lot has been accomplished in such a short space of time, there is still much to be done. I am confident that the country is on the right track and that it will continue to make progress in the years to come.

In terms of clothing, lifestyle, and independence, I have not experienced any significant changes since moving from Denmark to the Gulf—apart from the weather! I even have a Saudi driver’s license to explore this amazing country.

My move to the Gulf has been a life-affirming experience for me, both professionally and personally. On a personal note, I was diagnosed with multiple sclerosis a few years ago. This has played a role in my decision to move here, as it has given me a renewed sense of purpose and the desire to make a positive impact on the lives of others. I now live by the words of Nelson Mandela who said, “What counts in life is not the mere fact that we have lived. It is what difference we have made to the lives of others that will determine the significance of the life we lead.”

AT: Thank you, Farzana, for sharing your experience with our readers!