What: The proposed rule would require some investment advisers to apply certain anti-money-laundering and countering […]
It’s hard to believe that almost four (4) years ago, my partners and I developed the strategy and business plan that would ultimately lead to the launch of Compliance Risk Concepts (“CRC”), a compliance professional services organization, headquartered in New York City.
In the spirit of candor and full transparency, I didn’t wake up one morning with an epiphany, deciding I wanted to become an entrepreneur. Quite truthfully, I had been noodling on the idea of launching what eventually became CRC, five (5) years prior to it coming to fruition. This idea came from a very organic and natural place. As a former Chief Compliance Officer (“CCO”), I had been a “buyer” of professional services for a good portion of my 20 year “in-house” career. During this time, I watched closely - quickly learning what was truly wrong with the delivery model being offered by most consulting firms, whether they were Tier 1, Tier 2 or lower down the food chain.
So, what was wrong? In my personal experience, the problem began with the transparency of the delivery model employed by professional services firms. I don’t believe my findings were unique – and I would bet most people reading this article who have been “buyers” of professional services would concur their experiences were similar to mine. The lack of transparency I am referencing is embedded in the “sales model” of these organizations. When I was seeking an external provider to assist in a project, I often found that the impressive senior partner with the most relevant experience would be the individual pitching me on their firm’s capabilities and expertise specific to my need. The conversation would occur over a nice lunch or dinner - and I would walk away with my ego feeling stroked with a full stomach. Once I found the firm I believed would be the “best fit” for my project, the fun began…
Shortly after the project launched, I noticed something was amiss. The senior partner that I bonded with, (you know - the one that sold me on his / her firm’s capabilities and bought me a great meal) quickly disappeared into thin air and was replaced by a team of individuals with 2-3 years of consulting experience, straight out of college who had never walked a day in my shoes, did not understand the complexity of the businesses I was supporting, nor had not a clue in terms of how to execute against / mitigate the risk I was seeking to address. I felt as if I was paying an exorbitant price to train people how to do their jobs – with not much to show at the end of the day except some fancy PowerPoint presentations and an acknowledgement of the risk I already knew I had.
Based on this common theme, the decision to launch CRC ( in what I would call a highly commoditized space), came from a genuine desire to distinguish ourselves from the pack through the quality of services being provided in the regulatory compliance vertical. How were we going to achieve this? Quite simply, as we’ve grown as an organization over the last 3 ½ years, we had stayed committed and true to our operating model. We don’t hire any professional consultants. We only retain former CCOs and Senior Level Compliance Officers. The average tenure of our 15+ team members averages from 15-30 years in the financial services industry. We’ve all been in our clients’ shoes and have been in the “hot seat”. We are a “plug and play” provider that truly gets it. This truly resonates with our clients.
Equally (if not more important), we are a boutique organization employing a services model that is predicated on strong execution. We are not a “check the box” provider that merely acknowledges the existence of risk. If we are not solutions oriented thought leaders that can help our clients execute against and mitigate their discrete compliance related risks – we aren’t doing our jobs. Whether we are being retained as a full outsourced compliance provider or to undertake a discrete review of a certain aspect of a client’s business – we bring our “A” game and “A” team every day.
In closing, the best evidence of our model truly working is the satisfaction demonstrated by our clients through their loyalty and willingness to help tell our story when they encounter others in need of compliance professional services. This, in and of itself is the biggest reward that has come out of CRC - and something we are all extremely proud and excited to be a part of as we continue our mission and journey as an organization.