DOJ inquiry: feedback.
You’d rather sit through a four-hour records retention training than tell your deputy compliance officer that their investigation memos read like they were drafted during a fire drill. But here’s the reality: avoiding feedback is like ignoring a gap in your internal controls. The risk doesn’t disappear. It compounds.
Why Feedback Is a Compliance Risk and a Program Asset
Consider this: research consistently shows that regular, effective feedback increases employee engagement byover 60% and job satisfaction by nearly 80%. For compliance programs, that translates directly to program effectiveness.
When your experienced compliance analyst leaves because no one told them their risk assessment methodologywasn’t aligned with program standards, but they heard it “through the grapevine”, that’s a program risk. When a business unit leader stops engaging with your hotline process because no one follows up on their concerns, that’sa failure of the speak-up culture. When a key third party never hears that their due diligence documentation is consistently inadequate, that’s a liability.
Compliance is fundamentally a relationship-driven discipline. Trust between compliance professionals and the business, between leadership and their teams, between organizations and regulators, is built through honestcommunication. Feedback is the mechanism that keeps those relationships functional.
Why Compliance Professionals Struggle with Feedback
Compliance professionals are trained to identify risk, investigate facts, and advise leadership. But feedback is a different skill set entirely. A skill set most of us were never formally taught. Here’s why it’s particularly hard in the compliance world:
- Fear of conflict: In compliance, we already carry the reputation of being the “Department of No.” Layeringon difficult conversations feels like adding fuel to that In reality, the absence of honest feedback creates far more friction over time.
- Cultural considerations: Compliance professionals operate across industries, geographies, and organizational High-context and low-context communication styles differ significantly in how feedback lands. What reads as direct and constructive to one colleague may feel dismissive to another. Understanding these dynamics, not ignoring them, is part of effective compliance leadership.
- Lack of training: Most compliance professionals developed feedback habits from managers who either defaulted to the “sandwich method” or simply pointed out deficiencies and moved on. Neither approach builds the kind of trust a strong compliance culture requires.
The GIFT Framework: A Practical Tool for Compliance Professionals
Whether you’re managing a compliance team, coaching a business partner, or navigating a sensitive conversation with a board member, the GIFT framework offers a structured approach:
- G – Gain Permission: “Can I share an observation about how that investigation was documented?” Consent creates psychological safety and signals respect.
- I – Identify the Facts: Anchor the conversation in observable behavior and data, not interpretation.Reference the specific report, the pattern of missed deadlines, the audit finding
— not the person’s character or intent.
- F – Frame the Impact: Connect the behavior to program outcomes. “When investigation timelines slip past30 days without documentation, we’ve handed a regulator the exact narrative we don’t want them writing, and the program we’ve worked hard to build takes the hit.”
- T – Trigger Collaboration: End with a question, not a “What would help you meet that standard consistently?” You’re not issuing a finding, you’re building capability.
If frameworks feel cumbersome, remember this simpler formula: Actionable Feedback = Examples to Learn From + Advice to Act On. Specificity is what separates useful feedback from noise.
Feedback in the Compliance Context With your team:
When a team member consistently misses documentation deadlines, escalates every minor issue to
leadership instead of exercising their own judgment, or defaults to ‘no’ without offering the business a compliant path forward, those conversations cannot wait until year-end performance reviews. Timely feedback prevents the slow erosion of team cohesion and program credibility.
With stakeholders and business partners:
Business partners need feedback, too. When a division leader consistently bypasses the compliance review process, or when a vendor’s certifications are perpetually late and incomplete, a well-framed conversation is bothappropriate and necessary. Protecting your program’s integrity sometimes means delivering feedback upwardly clearly, professionally, and with documentation.
With yourself:
Model the behavior you’re asking of others. Request feedback from your team, your business partners, and your leadership. This isn’t just good management: it’s an ethics statement. How you respond to candid input tells your organization far more about your values than any code of conduct you’ve ever published. If you can’t take the feedback you’re asking others to absorb, the culture you’re trying to build will lack teeth.
Building a Feedback-Driven Compliance Culture
The DOJ’s guidance on evaluating corporate compliance programs specifically asks whether a complianceprogram is “empowered, adequately resourced, and independent.” An effective feedback culture is part of what makes that true. Programs that operate in silence, where concerns go unaddressed, where performance gaps go unspoken, where honest dialogue is avoided … are fragile programs!!!
Normalize feedback as routine practice. Let’s say it again together: normalize feedback as routine practice.Balance candid course-correction with genuine recognition of strong work. And stop saving every important conversation for annual review cycles!
The Bottom Line
For compliance professionals, feedback is a core competency. It is the mechanism that builds trust, making ethicsand compliance programs work with teams, the business, and the organization at large.
Regulators, boards, and leadership all want to know that your compliance program is embedded in the organization’s culture. A program built on avoidance, including avoidance of difficult feedback, is not!
So, embrace the F-word. Your program, your team, and your organization’s integrity depend on it.
