Jodi Golinsky, deputy U.S. general counsel for Wonga U.S.
Having worked at a number of financial services organizations in her career Jodi Golinsky, deputy U.S. general counsel for Wonga U.S., has a wide range of experience. This experience has given her a unique perspective on the financial services sector and the regulatory matters that are top-of-mind for compliance professionals in that industry.
“The primary issue over the last decade relates to consumer fairness and protection,” Golinsky explains. “This can take different forms, from identity theft to fraud and more.” Dodd Frank plays a huge factor, of course, but, she says, concerns like identity theft and privacy have been significant regulatory issues for quite a while now, as have concerns about consumer fairness.
Golinsky has worked for companies with international footprints, and sees a lot of common ground here and abroad. “In many cases, issues tend to be the same, or an issue that is emphasized in one country gets sent to other countries. You see a lot of the same issues abroad that you see here,” she says. Some of the biggest concerns for companies that work abroad are sanctions lists, bribery and money laundering, and issues like privacy, data usage and protection are prevalent as well.
But even for companies that only do business in the United States, there are a host of complexities to deal with. There are state and federal laws to navigate, which means there are potentially 52 different sets of rules and laws (including the District of Columbia) that companies must look at, which makes the U.S. a tricky market.
In order to build a robust compliance program, Golinsky stresses that proper resources are essential. “You need enough people to run it and manage it,” she says. “It’s difficult to have a robust program if you are understaffed.” Since compliance is so closely tied to business objectives, it’s best to involve other departments in all stages, the earlier the better. Setting the right tone at the top is key as well, creating a culture of compliance. Additionally, companies should commit to rigorous risk assessment and testing, and ensure that policies are well thought out and properly monitored.
As for the relationship between compliance and legal, Golinsky sees the two departments going hand-in-hand. They have different functions, of course, but any well run company needs to have strong legal and compliance departments. Since they work together all the time, there needs to be a relationship between the GC and the chief compliance officer (CCO). The CCO should also have direct interaction with the board, as sometimes the leaders at the top of the chain need to hear directly from the CCO on compliance issues.
“A good CCO needs to be someone who is detail oriented and can see the big picture, with good judgment on risk assessment and litigation,” Golinsky says. She also believes that a strong CCO should be creative and have a thick skin. And, if you are a successful compliance officer, you have the pleasure of helping the business grow, which can only be good for the company and your career.
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