CCO PROFILE: PETER BLUMBERG
R&C: What pivotal experiences have shaped your approach to compliance or risk management throughout your career?
Blumberg: During the first part of my FedEx legal career, I worked in our litigation group, which included representing the company in matters brought by government agencies, as well as responding to external investigations involving US federal and state regulators. The perspective of utilising the company’s compliance efforts in the context of defending the company has been invaluable in how I approach evaluating risk and developing and implementing compliance programmes. There are learnings that come from having to ‘prove it’ to an enforcement agency or a court – or even a jury – that informs how you develop, implement, monitor and test policies and programmes. There are no better means to appreciate the need to fully document every aspect of a programme until faced with responding to an investigative demand, subpoena or civil discovery request.
R&C: How do you navigate complex regulatory environments and evolving legal frameworks? What guiding principles inform your decision making?
Blumberg: With changing legal and regulatory environments, the key is to assess and evaluate precisely what is motivating or driving the change. What goal is the agency trying to accomplish? What conduct is it seeking to prevent or encourage? What past misconduct occurred that is motivating the new requirements? Focusing on agency intent and goals usually reduces the complexity or at least assists in breaking it down to core principles. Not only does this aid our decision making and evolving the company’s compliance framework, it also helps with educating and engaging business partners.
