The Grinch Who Stole Compliance
A Publication in Foley’s International Trade, Enforcement & Compliance regulatory series.
Happy Holidays! We are hoping that everyone has gotten in all those last-minute CLE credits and finished holiday shopping for that special someone who is looking for compliance training aids under the Christmas tree. And for anyone who is wondering which of the classic holiday specials to watch, our suggestion is to watch the one that provides the most compliance-related learning. We mean, of course, that you should watch . . .
The Grinch Who Stole Compliance
Every Who down in Workville liked Compliance a lot . . .
But the Grinch, who toiled from his home office, did NOT!
The Grinch hated Compliance! In every season!
Now, please don’t ask why. No one quite knows the reason.
It could be his morals weren’t screwed on just right.
It could be, perhaps, his shoes were too tight.
But I think that the most likely reason of all,
May have been his expense account was two sizes too small.
Whatever the reason, his expense account or his shoes,
He stood there dreading Compliance Week, hating the Whos.
And most of all he hated the pretentious Compliance Whos!
Who saw compliance in black and white, and never chartreuse!
Staring down from his mancave with a sour, Grinchy frown,
At the warm lighted conference rooms below in their town.
For he knew every Compliance Who was planning a compliance review,
They were toiling away to prepare Compliance Week slides all anew!
And whether it was in person, or just over Zoom,
He knew that he would hate it all, and so very, very soon!
“And they’re adding compliance cartoons!” he snarled with a sneer,
“And overusing PowerPoint effects! I can see it so clear!”
“One slide is spinning, and the next one is morphing,”
“I couldn’t stand it again, not even with four shots of morphine!”
Then he growled, with his Grinch fingers nervously drumming,
“I MUST find some way to stop Compliance Week from coming!”
For tomorrow, he knew, all the Who women and men,
Would wake bright and early. For Compliance Week, they’d rush in!
Being late to Compliance Week, why that would be a sin!
For mini-bagels and compliance presentations, they wouldn’t just Zoom in!
“I MUST stop this Compliance Week from coming! But HOW?”
Then he got an idea! A non-compliant idea!
THE GRINCH GOT A WONDERFUL, NON-COMPLIANT IDEA!
“I know just what to do!” The Grinch laughed in his throat.
And he made a quick Santy Claus hat and a coat.
Then the Grinch took his hastily built Santa sled down to the Workville Town Square,
And he entered Workville headquarters to begin his anti-Compliance Affair!
“This is stop number one,” the old Grinchy Claus hissed,
And he entered the conference room with a non-compliant clenched fist.
“These PowerPoints,” he grinned, “are the first things to go!”
And the small mini-bagels, and the compliance break cookies, were the next things he stowed.
And he went around the room and took the presentation projector!
And the mouse! And the speakers! And the HDMI connector!
And he stuffed them in bags. Then the Grinch, very nimbly,
Stuffed the bags up the never-before-seen chimney!
“And NOW!” grinned the Grinch, “I will stuff up the conference room table!”
And the Grinch started to push, as hard as he was able.
When he heard a small sound, expressing concern.
It was the sound of a hard-working intern!
Little Cindy Lou Who, who was not even twenty-two.
Who had always dreamed of becoming a good corporate Who!
She stared at the Grinch and said, “Santy Claus, why?
Why are you taking our Compliance things? WHY?”
But, you know, that old Grinch was so smart and so slick,
He thought up a lie, and he thought it up quick!
“Why, my sweet little tot,” the fake Santy Claus lied,
Using triggering language HR certainly would mind!
But the Grinch didn’t care, as he spun his great lie.
He smiled and said, “These things won’t access encrypted Wi-Fi.”
“So I’m taking them home to my workshop, my dear.
I’ll fix it up there so you hear crystal-clear.”
And his fib fooled the intern, who’d watched too much Tok and the Tik.
So by the time he finished, she’d moved to the next topic!
Then the last thing he did was change the compliance quiz on the white board.
So it said if you stole from your boss you’d get a high score!
It was quarter past dawn . . . all the Whos were still dreaming,
Except Cindy Lou Who, who was internet meming.
And he left with all things, and even took their Compliance controls!
The Code of Conduct! The Policies! Their ESG goals!
Three thousand feet up! Up the side of Mt. Crumpit,
He rode with their compliance, planning to benchmark and dump it!
“Pooh-pooh to the Whos!” he was grinchishly humming.
“They’re finding out now no Compliance Week’s coming!”
“They’re just waking up! I know just what they’ll do!”
Without their Compliance policies it will all go askew!
Not a single one will know what to do!
And the compliance problems, they will suddenly accrue!
Then he looked! What he saw was a shocking surprise!
Everyone still worked, in a compliant enterprise!
Every Who down in Workville was working! Without any controls, large or small.
But ethically! With no whistleblower concerns at all!
He HADN’T stopped Compliance Week from coming! IT CAME!
Somehow or other, workers worked just the same!
And the Grinch, with his grinch-feet ice-cold in the snow,
Stood puzzling and puzzling: “How could it be so?”
“It came with no training, no CLE credit!
No bagels or compliance quizzes from Compliance Askreddit!”
And he puzzled three hours, till his puzzler was sore.
Then the Grinch thought of something he hadn’t before!
“Maybe Compliance,” he thought, “doesn’t come just from one training.”
“Maybe Compliance . . . is long-term and self-sustaining!”
And what happened then? Well . . . in Workville they say,
That the Grinch’s compliance metrics grew three sizes that day!
And the minute compliance constraints didn’t feel quite so tight,
He brought back compliance through the bright morning light.
And he brought back the bagels and the HDMI connector!
And he personally hooked up the compliance projector!
And he, HE HIMSELF! The Grinch gave the Compliance Week speeches!
And that year there were no compliance lapses or breaches!
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