I remember from my military days having station inspections where high ranking officers would come and see how the station was looking and operating; visits were always seen as bit of a farce because the station would go into overdrive to get things up to scratch when they should have been up to scratch already.
These high ranking officers would clearly have known that extra time and resource would have been allocated to get things up to scratch ready for their visit so would have been aware of the ‘cosmetic’ nature of the inspection.
Compliance within many law firms could be viewed in the same way!
I know there are many law firms out there that are doing their utmost to comply with their regulatory obligations, not just to stay safe from their regulator but also because they know it is good business. But I also know that there are many firms that will be looking to play the ‘cosmetic’ game in that they will wait for a regulator’s visit letter before getting their house fully in order.
The problem for these firms is that the SRA will be able to see or ask questions that will tell it whether compliance is ‘cosmetic’ or whether it is well established.
Cosmetics can only cover things up for a short period of time but after a while people will start to see through them as the wrinkles start to show through; it is then that reality hits home and the truth comes out!
Firms should consider where some of their wrinkles could appear, for example, would all staff give the same compliance message if asked questions by the SRA or would they show that the compliance message only goes down to certain levels of the organisation?
If you are worried that your firm may be seen as having a “cosmetic” compliance regime please contact me; I have created a quick action checklist that will help you uncover the key areas you need to focus on to ensure a robust approach. To obtain the checklist please email firstname.lastname@example.org
Riliance can help firms to ensure they don’t need ‘cosmetics’, and can look good no matter what time of day someone looks at them!
Produced by Brian Rogers, Director of Regulation & Compliance Services, Riliance.