Often, Perdue said, an organization's leadership is puzzled when staff members fail to follow compliance directives. In many cases, leadership doesn't understand that their lack of meaningful involvement is the source of the problem, she added.

"Telling is not the same as training, expecting is not the same as guiding and dictating is not the same as leading," Perdue said. "Compliance is a culture, but one without a consistent definition. It requires a principles-focused approach to be successful."

Compliance is much more than just directing resources, Perdue said. Everyone has to be in alignment in order to achieve compliance procedures that are embedded into existing workflows, achieved with a minimal amount of friction and result in few or no examiner criticisms.

Good compliance efforts should also be evident in their structure and intent so that examiners can see and understand what an organization is doing to meet and exceed compliance goals, Perdue said. There is a distinct difference between being merely compliant and developing a strong compliance culture that not only satisfies the needs of the regulator, but also serves the strategic goals of the organization.

"When the actions of your organization finally go from 'don't break the law' to 'do the right thing,' then you'll know that you're on to something," she said.

Perdue outlined five principles that define an effective compliance culture:

1)     A compliance culture is obvious in its presence and pervasive throughout the organization's culture. The compliance officer takes an obvious and active role across organizational projects, business units and initiatives to make sure that compliance goals and objectives are frequently and successfully met within daily operations.

2)     A compliance culture is invisible to the degree that it is always present and successfully embedded within each business process.  It shouldn't be obvious, but rather omniscient in its integration and influence within operations.

"When I was young I didn't like vegetables, but I loved spaghetti sauce," Perdue recounted. "My mother would puree vegetables and add them to the spaghetti sauce, and it wasn't until I learned to make the sauce myself that I realized what she was doing. Compliance is a lot like those pureed vegetables."

3)     A compliance culture is dynamic in its ability to change with organizational conditions and needs, and it doesn't function as a roadblock between progress and performance. A good compliance culture anticipates, prepares for and helps guide critical changes within the organization. In the end, a strong compliance culture can enhance performance and profitability through its dynamic capabilities to manage change.

4)     A good compliance culture is "business-aware," operating as a strategic advantage rather than a "check-the-box" exercise. The best compliance cultures are built around driving revenue and growth, while working hard to avoid illegal and high-risk situations that could have a negative impact on the organization.

 "If you treat compliance like a strategic advantage and perform well within its guidelines it will create a competitive advantage for your institution," Perdue said.

5)     A strong compliance culture is outcome-based, rather than rule-focused. To achieve those desired outcomes, the culture must be based on principles and communicated in language that everyone can understand and embrace. If everyone understands what the organization must due to achieve its goals within the compliance framework, successful efforts supported by a strong culture are more likely to occur.