20/06/2026
Most compliance frameworks are designed to define what “good” looks like.
They set out rules, controls, and escalation paths.
What they do not define clearly is how those rules are applied in real decisions.
In this week’s RiskMasters, Jennifer Geary and Natalie McManus-Barnett, FCCA, F**A discuss this in the context of their book, How to Be a Chief Compliance Officer.
One point from the conversation stood out.
Compliance rarely breaks at the level of policy.
It breaks in how trade-offs are made under pressure.
• A decision is accelerated to meet a deadline
• A control is interpreted differently to maintain momentum
• A concern is acknowledged, then deprioritised
Each action is defensible in isolation.
Taken together, they shape outcomes that no framework explicitly intended.
This is where the role of the Chief Compliance Officer becomes critical.
Not in defining the rules.
In influencing how they are applied.
As Natalie McManus-Barnett puts it:
“Compliance is not about rules first. It starts with understanding harm.”
That shifts the focus.
→ From compliance as a checkpoint
→ To compliance as part of the decision itself
→ From monitoring activity
→ To shaping behaviour in real time
This is where many organisations struggle.
Signals do not arrive neatly packaged.
They sit across teams, contexts, and competing priorities.
Acting on them requires judgement, credibility, and persistence.
🎓 In this episode, we explore:
• What the Chief Compliance Officer role looks like in practice
• How compliance influences real business decisions
• Where frameworks lose traction under pressure
• The IMPACT Wheel and how it connects compliance activities
• The capabilities shaping modern compliance leadership
The question is not whether the framework is robust.
It is how consistently it holds when decisions become difficult.
💬 How does that play out in your organisation?