The Importance of Cultural Fluency in a Compliance Team

Navigating and being part of an international team in the compliance industry can be challenging. Not only are you expected to be a subject-matter expert, but you must also possess impeccable cross-cultural skills for a smooth and successful project delivery to management as well as to various regional and cross-jurisdictional stakeholders. Today, a global business is more interconnected, highly regulated and increasingly observed than ever before in world history. Companies work and influence across international borders, which in turn makes them focus on regional regulations, peculiarities, customs and last, but not least, culture.

Culture has become an instrument of branding and a barrier between people. Therefore, cultural fluency is needed for all types of international relations, including economic ones. But what does it entail? Speaking foreign languages and being a globetrotter might not be enough for a successful cross-cultural interaction. Cultural fluency is much broader than a mere language. One might be fluent in a language but might not be able to navigate that language successfully in cultures where it is spoken as the native tongue. Cultural fluency is the awareness and ability to fully comprehend that some people belong to their native cultures, some are bi-cultural, some are culturally ambiguous (neutral), while others do not identify with any culture at all. Multiculturalism is what the interconnected but disconnected, globalized world needs.

In compliance, cultural fluency is the ability to process generic information in the various cultures where the teams operate, understand their complexities and connect communication and execution styles in work-related matters. It is also about knowing when team members start using the culture card that can harm others in the team or anyone outside of it. A team in country A cooperating with the team in country B that must first receive information from the team in country C may have complications in delivering compliance-related requests, especially if their realities and perceptions are far from one another. Risk forecasting, assessment and management also differ in both a regulatory environment and local culture. How teams view risk is again inherently connected to the financial history of their jurisdiction. Their interpretation of deadline, hierarchy and authority vary.

The following are steps to enhance cultural fluency in your compliance team:

  • Overcommunicate: Athough English has become a lingua franca, a sender and a receiver of the message in two different parts of the globe will interpret it locally. Sometimes a seemingly concise and concrete communication needs to be overclarified and overcommunicated for a clearer understanding as well as for transparency. In my daily job, I interact with both English and Russian language native speakers. While these two are not my mother tongues but rather languages I grew up learning and speaking in addition to my native Kazakh, I fully understand both the communication styles, technique, vocabulary usage of both sides and do my best to help them understand one another. Writing an email in Russian may end with an exclamation mark and without a “thank you” unless someone actually did something. For emails in English, having an exclamation mark after each sentence may seem impolite unless it is a “congratulations!” and it is highly likely they end with a “thank you,” regardless of request delivery status. Official Russian language correspondence is direct, very concrete and rarely includes “please.” Meanwhile, in English, there are many ways to express even negative emotions in a manner that it may sound pleasant to the non-native user. That is not to say one group is better or worse than the other, rather we should understand how native speakers use languages.
  • Do not react on the table: Remind yourself that any emotion is healthy if managed correctly. The environment impacts how people react to change, decisions and determinations. A delicate and diplomatic delivery of information can be a way to lessen unpleasant atmosphere. Once a colleague made the following statement as we were discussing task division of the workload, “Women your age and your race just starting their career don’t speak up.” I spoke anyway, related to the discussion, and did not react to the statement. However, after the meeting, calmly and concretely, I replied, “I don’t derive my sense of self from my group membership, sir. We should not be bothered by one another’s groups .’’
  • Integrate instead of imitating: Just like a regulation in territory A cannot be fully functioning in territory B, professional culture also cannot be a one-size-fits-all. Nevertheless, intercultural communication in one team could be a balancing act. As a nomad, I realized many people when moving across borders tend to imitate the host culture’s lifestyle, modus operandi and even accent. In one of the positions I held, a new peer of mine was going above and beyond in order to copy the “established” team members’ behavior and it did not work personally nor professionally. That sense of acceptance we all wish for can be achieved without imitation by being merely authentic with willingness to adapt and evolve.

We should all learn to work and represent the institution we work for; the company culture should be our only culture during performance of the job. We may take our historical cultural identities outside the office for the greater good,—peace and success of our teams. Within a financial industry, like in any other, you could be a pilot with an attitude of the passenger or a passenger with an expertise of a pilot—whoever you are, practice sufficient emotional and ethical sophistication to stay calm and compliant when facing cultural turbulence in your cross-border compliance team.

Diana Madibekova, a full-time compliance officer and a part-time columnist who believes cultural ambiguity is actually a thing, Warsaw, Poland

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