Compliance Training and Cat Videos
Updated: Sep 8, 2020
The following interview is with Ricardo Pellafone, Creative Director & Founder, The Broadcat, www.thebroadcat.com
RTB: Tell us a little about your background and current work.
RP: I’m an investigator-turned-compliance-startup-founder, with pretty much my entire career being spent in compliance.
I started off as outside counsel about ten years ago, where I developed a niche in doing compliance investigations. That ended up taking me to an in-house compliance job for a sovereign wealth company in Abu Dhabi; after that, I was a director on the compliance team at a Fortune 200 tech company in California. And now I’m in Dallas, where I lead my company, Broadcat; we make simplified, task-oriented training.
So, short version, I’m a compliance professional that likes to live in places with painfully hot summers. I grew up outside of Detroit, so I’m just happy to never hear the phrase “lake effect weather” ever again—which, if you’re unfamiliar, is a Michigan euphemism for “you could cry about how cold it is, but your tears would freeze your eyes shut.”
RTB: Why did you move from investigations into training?
RP: I’m trying to solve a problem I’d had—that most training doesn’t seem to translate to real life. I’ve done investigation interviews where a front-line employee remembered training and could correctly recite the guidance, but had zero understanding of how that would translate to their actual job tasks.
That is—and this is compliance jargon, here—“not awesome.”
It’s good to be able to show that people certified to training, but training isn’t an end in itself; the purpose of training is to increase compliance. And to increase compliance, training has to translate to the real world.
My pre-law degree was in psych, so I dragged out the social science on transfer—how we go from learning something to actually using it. I then started developing my own training, and that eventually turned into Broadcat.
We make materials that are framed around real-world tasks; for example, I don’t make learning modules on anticorruption or cybersecurity or whatever, because only compliance people and lawyers think in terms of abstract risks like that.
Instead, we make task-oriented stuff like “here’s how to review an invoice for red flags” and “here’s how to detect a phishing email,” and then we give them to companies in formats that they can edit and customize themselves. Here’s an example of one of the pieces we license.
RTB: You tend to write a lot about simplicity. What is that, and why is it important to compliance?
Simplicity is kind of the word of the moment in compliance, but I think it’s usually used incorrectly. It’s often used to describe things that are just easy to understand or engaging—and of course, both of those things are incredibly important in anything you do.
But simple things are first and foremost useful. So when I talk about simplicity, what I mean is that you’re doing something that directly relates to the goal of compliance—helping front-line people do their job tasks compliantly.
The reason it’s important is because increasing front-line compliance is the whole point. If you’re giving training that is engaging and easy-to-understand but doesn’t help front-line employees do their jobs compliantly, you might as well be sending them cat videos from YouTube.
Actually, the cat videos would be better, because they’re free and everyone loves cat videos.
And, obviously, it’s also important because it’s what the government is telling you to do, and they tend to, you know, enforce the laws and such.
RTB: Can you give an example of that?
RP: Sure. Laura Jacobus at LRN recently did a really nice interview with Hui Chen, the DOJ’s compliance expert. When Laura asked Hui how she knows if a company has a real or paper compliance program, here’s what she said (in part):
“I also look to see how the most front-line workers understand their jobs: Does the clerk in the accounts-payable room understand his job to be processing payments as quickly as he can, or does he understand that he is supposed to keep an eye on certain things and escalate issues he identifies? Does the new salesperson understand her job to be making the deal at all costs, or does she understand that there are boundaries?”
Those are great questions—because that is actual compliance.
But there are companies that have amazingly polished Codes of Conduct and elaborate e-learning systems that can’t answer them. And we have a name in the compliance world for companies that have award-winning training materials but no front-line compliance: Enron.
RTB: So if a company is just starting out in compliance, what advice would you give to a compliance team in keeping things simple?
RP: Two things, I think.
First, be ruthless in setting your priorities and remember that your job is to increase front-line compliance, not do stuff just because other companies are doing it. If you have a newsletter and e-learning and an interactive Code but no one on your team knows how your salespeople close deals or your accounts payable folks review invoices, you’re doing it wrong.
Second, and related: focus on getting to know your business processes really well. As in-house compliance, you’re the only person that can figure out how your people review invoices, or set pricing, or ship prototypes—and those are the things that will determine whether you’re compliant. You can outsource everything else, but that’s your unique niche, and that’s where you need to focus.
RTB: Thank you Ricardo, how can people contact you?
RP: Our website is thebroadcat.com, and that’s our handle on LinkedIn, Twitter, and Facebook too. You can also contact me directly by shooting me a note at firstname.lastname@example.org