We sat down with Martin Schofield, financial crime prevention and compliance specialist, to see how behavioural science can benefit the compliance industry.
Picture the scene…
You and your colleagues file slowly, languidly into the training room. There’s a whiteboard. There’s tea and coffee. There are even snacks. Yet there’s also a slight tension in the air.
Perhaps that tension is because at some point there will be a test on what you’re about to learn. Or perhaps it’s because before that, before your test, you’re going to have to put your hand up and talk about yourself – revealing your biggest fear or some other deep rooted secret – to the rest of the room.
If the very thought of this makes your palms go clammy, you’re not alone.
Glossophobia, the fear of public speaking, is estimated to affect somewhere between 40% and 70% of us. Going into a room for mandatory training – whether in compliance or something else – and being asked to publicly reveal some innermost secret can make many of us uneasy. Plus: tests. Lots of us don’t really like those, either.
Glossophobes welcome
So it’s lucky we have trainers like Martin Schofield around. He’s been training teams in compliance for the last 25-plus years. A financial crime prevention and compliance specialist – with a background that includes money laundering and fraud prevention, sanctions compliance, audits, investigations, policy authoring and plenty more – he’s developed a portfolio of techniques to put learners at ease.
First up, when he enters the room, he tells attendees there will be no test. “Ideally I’d assess in three to six months after training, so it’s embedded, not just remembered,” he says.
Next, there will be no great ‘reveal’. There’s a reason nobody knows a certain secret something about yourself, says Martin, and that’s because you don’t want others to know it. Plus, he adds: “For some people it’s their worst nightmare, just to raise their hand.”
While announcing this to the room – no test, no personal revelations – he sees people’s shoulders visibly drop. All of a sudden they’re not guarded. They relax. They’re now in learning mode.
The ‘accidental’ behavioural scientist
Audiences can be tense when it comes to training – and that’s especially true when it comes to mandatory compliance training, often viewed as a starchy, uncompromising business. For many, it’s a sector full of rules, regulations, directives, punishments, fines and other menacing terms.
So, the whiteboard that’s in the room? Once everyone has filed in and is sitting down, Martin will trip over it. He doesn’t need the whiteboard to be there, he might not even use it, but he always asks for one so that he can stumble over it.
“I trip. They laugh. And they think, ‘Because he’s made an idiot of himself, I’m free to do the same.’”
Or he’ll mis-pronounce something.
“In the anti-money laundering world we talk about ‘extra-territoriality’ so I’ll always mess that word up: ‘extra-terrestrial … extra-tra- what’s the word?’” says Martin.
The behavioural scientists among us may recognise this as the pratfall effect. A psychological construct where a highly competent person is seen as more likable after making a small transgression. A transgression like tripping over a whiteboard. Or failing to pronounce extra-territoriality.
Flawless perfection, goes the theory, can be intimidating. Make a bit of a fool of yourself and that intimidation vanishes. Plus, it means that people open up more, are more likely to answer questions, and, therefore, are more likely to learn.
Turning these techniques into something more tangible
Martin has used these techniques throughout his career. Yet it’s only lately that he’s started using these techniques more intentionally and under a science-backed umbrella. He recently completed the BEHAVES academy course and is, in his words, “a convert”.
“While taking BEHAVES I was thrilled to see that what I’d actually been doing my whole life has got a name. I have learnt much more since taking the course and the first thing I have learnt is to use these insights with confidence. These are not just terms and ideas I have come up with over the years or overheard at dinner parties.”
Having that structure, says Martin, has been a revelation: “These are real things that sit within frameworks and are surrounded by years and years of research.”
In fact, the BEHAVES course has been a “gift” that has given Martin both vindication and validation.
“I wish I knew some of this stuff before, for some of the debates I used to have. So I could have said, ‘It’s not just me saying this, there are frameworks that fit around this.’ Now I’ve got all of these tools: what I thought was a good toolkit has become an amazing toolkit”
Putting behavioural science into policy documents
So, when it comes to compliance, how can behavioural science step in and help? First of all, says Martin, we need to address some misconceptions.
“The biggest thing people in compliance [i.e. compliance officers] forget is: employees aren’t employed to do your job. Your job is compliance, their [employees] job is what they do day-to-day, whether that’s admin, project management, writing policy documents …”
Ah, yes: policy documents, an area ripe for a behaviourally informed makeover. Policy documents may be executed in pristine, surefooted legalese – but such legalese is unlikely to win over readers. This highlights a fundamental tension. Often, policy documents will be written for the regulator – “Worded so that the regulator goes, ‘Ooh, this is a really good policy,” chirrups Martin – but policy documents should be written for people to actually read and recall the material, not for regulators to be wowed.
Okay, full disclosure. Martin not only took the BEHAVES course, but also was part of the review team who assessed our brand new, one-of-a-kind course, “Achieving compliance with behavioural science” – and is keen to highlight the module on messaging.
The beauty of using behavioural insights in messaging, he says, is that it puts the recipient of the messages first and foremost. When it comes to policy, says Martin – heck, when it comes to any written compliance communications – you need to always be thinking of the intended audience.
“Don’t think about what you want to say or write,” he says. “Think about what they [your readers] are going to read or hear.”
This is an approach the Financial Conduct Authority (FCA) has embraced with unbridled enthusiasm. One of their key directives says Martin is ‘What is the right outcome for the consumer?’ and they also give a lot of thought to how to present these outcomes.
“If you look at the communications coming out of the FCA, they’re so relaxed in language and tone. They’re talking normally, they’re talking ‘street’. So why does policy [writing] have to be so stuffy?” he says.
Shaking up the status quo
The FCA has a practice of making sure communications in the industry are clear, fair and not misleading. That can be extrapolated to all communications in the industry. If all communications are judged to that criteria – clear, fair, not misleading – before going out into the wider world then, says Martin, communications automatically become so much better.
Understand human behaviour better and better results follow. It’s an appealing equation. Viewing compliance practices through a behavioural lens – rather than the carrot and stick approach – could be a big part of the future of the industry.
“Compliance has typically carried with it a comply or die ethos,” explains Martin. “Compliance says and the business does. More and more penalties are applied for non compliance and bigger sticks are secured to act as a deterrent for not complying in the future.”
Yet that’s not always the right approach, and it’s this status quo bias that needs a shake up. “The regulators require firms to look at outcomes based compliance for a firm’s customers, but not its employees. One can’t help but wonder what positive differences would be seen if an employer used the same external [behavioural] lens internally.”
The benefits of a behavioural lens
So how does a course like the one the BEHAVES Academy has co-developed with the Association of Governance, Risk and Compliance (AGRC) help? One way, says Martin, is that viewing compliance practices through a more behavioural lens can give compliance professionals the gift of “assurance”. It can also offer a fresh perspective, one informed by decades of science.
“Different ways of doing things and viewing things can not only be safe but also successful,” says Martin. “For too long Compliance Teams have sent out their dictates and wondered why they are not always followed, or followed entirely, let alone followed with pleasure.”
And can this course help with that – to make compliance not only more optimised and effective but also, possibly, more pleasurable? Apparently so.
“Achieving compliance with behavioural science gives Compliance Teams the ability to add new and effective tools to their toolkit, ones. that will help them achieve compliance each and every time.”
“Achieving compliance with behavioural science gives Compliance Teams the ability to add new and effective tools to their toolkit, ones that will help them achieve compliance each and every time.”
Each and every time? Thanks Martin, that’s high praise indeed. We’d love you to take a look at the course here and tell us if you agree.
Martin Schofield
Martin is a Fellow of the International Compliance Association (ICA) and the Association of Governance, Risk and Compliance (AGRC) and has spent time working as an Economic Crime Consultant to two UK Police Forces.
He has also worked on behalf of the Ministry of Justice, as a member of the Independent Monitoring Board of Prisons and Detention Centres and is currently in the process of applying to become a Court Magistrate.
Find out more about him and the training services he provides on his website here.
Martin Schofield
Martin is a Fellow of the International Compliance Association (ICA) and the Association of Governance, Risk and Compliance (AGRC) and has spent time working as an Economic Crime Consultant to two UK Police Forces.
He has also worked on behalf of the Ministry of Justice, as a member of the Independent Monitoring Board of Prisons and Detention Centres and is currently in the process of applying to become a Court Magistrate.
Find out more about him and the training services he provides on his website here.
