How to Advance Your Career in Compliance

Doctor, firefighter, marine biologist, compliance officer?

We're not sure the last one makes many kids’ list of their dream careers, but here we all are!

We love learning about how people got into compliance and how they continue advancing their knowledge in the field. That’s why we invited Steve Naughton to join us for this episode of Compliance Conversations.

Steve has held numerous high-level roles in the compliance field, from working as the in-house lawyer for Quaker Oats, to serving as the Chief Compliance Officer for both Pepsi and Kimberly-Clark. He also held roles working alongside compliance legend Larry Thompson. He now serves as the Director of Regulatory Compliance Studies and Clinical Professor at Loyola University Chicago Law School.

Join us for this episode, “Making the Grade: Compliance Career and Education Opportunities,” as we discuss:

    • Education and certification programs designed for compliance officers
    • Why compliance roles aren’t just for lawyers
    • The growing need for clinical and technical expertise in compliance

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CJ and Steve discuss how to get into a career in compliance, new educational opportunities designed for healthcare compliance, and what the future holds for this critical profession.

Compliance Conversations - Steve Naughton

Episode Transcript


CJ Wolf: Welcome everybody to another episode of Compliance Conversations. I am CJ Wolf with healthicity and I'm excited to have this episode today. I think a lot of a lot of our listeners are going to find this interesting as well. My guest is Steve Naughton. Welcome, Steve!  

Steve Naughton: Thank you, CJ. Nice to talk to you.  

CJ: Nice to have you. And today's topic everybody is we're going to talk a little bit about some formal compliance education programs and things that might help your career advance in the compliance field and Steve has some expertise there.  

Steve, we love it when our guests take a moment to introduce themselves and you know none of us grows up thinking, "Hmm, how can I end up in a compliance career?" None of us knows about it and we'd love to hear about your path a little bit and about how you've gotten there.  

Steve: Sure. That's great. I did hear one of the old saws at some of these compliance conventions that "We now know what school crossing guards grow up to be," so, I thought that was pretty spot on. I did not start out my career thinking that I would be a compliance officer and matter of fact when I started my career many years ago, I'm not sure that compliance was even in the eye of Congress or any of the congressional committees.  

CJ: Right.  

Steve: I am a lawyer by trade.I came out of law school at Notre Dame, where I went to work at a firm here in Chicago, met my wife, Nancy, and one of us had to leave the firm by our choice, not by hers. And I moved on to another firm; Pope, Ballard, Shepard & Fowle, a grand Old Firm in Chicago that made it to 98 years and then I was elected partner and literally at the meeting that I was supposed to attend to come in as a partner, there was a vote to dissolve the firm, so that was my claim to fame, but it actually opened a couple of different doors, which was terrific.  

I went from there to become an in-house lawyer at the Quaker Oats Company here in Chicago, led their litigation group, and did a good amount of business and corporate work in-house for Quaker, and Quaker was purchased by Pepsi in 2001, and that's when I went over, I made the move with the rest of the legal team at Quaker from being in-house for Quaker to being in-house of Pepsi.  

And within a couple of years of that, the legendary Larry Thompson was the general counsel, became the general counsel at Pepsi, and said, "Hey, we're really looking to stand up a compliance group and independent compliance group, we actually had a couple of people that were working in that group and said, "Would you like to move over to that?" And I did and I served as Pepsi's chief compliance officer for, I think the better part of about eight years. And I was I commuted back and forth from Chicago to purchase New York and had the great pleasure and honor of working for Larry, whom many of the listeners may recognize that name as the author of the Thompson memo and really one of the, to me, if you're going to have a Mount Rushmore of compliance officers or compliance figures, Larry would be on that list of a terrific supporter of compliance.  

CJ: Yeah, nice.  

Steve: And then I moved over to litigation, where I was head of Pepsi's litigation group for, I don't know, about a year and a half and decided I'd really wanted to get back into compliance again and moved up to took a job and went up to Kimberly-Clark and I was Kimberly Clark's chief compliance officer for, I guess, three, three and half years. And then from there, I went back and worked for Larry Thompson again, who became the monitor on the Volkswagen case.  

CJ: Okay, interesting!  

Steve: Yeah, and so, he was on the Volkswagen case, and I was on his team for three years. The monitorship came in on time and came in under budget, which doesn't happen very often for particularly monitorship that size. And then after that I started working, I'm now the director of regulatory compliance studies at Loyola University Law School here in Chicago, and I also do have a consulting practice. I work with the gentleman, Mike Volkoff, The Volkoff Law Group, and do work basically in compliance and investigations with Mike. But my primary job is as the Director of regulatory compliance studies at Loyola Law.  

CJ: That's so great, I appreciate you sharing that. And you know, Steve and I have kind of a Chicago connection. We both grew up in the suburbs of Chicago. You mentioned Quaker Oats. I had grandparents and family who lived in the city and we would drive in on, I guess that's the Kennedy Freeway, and there was that Big Quaker Oats' Building right off the freeway. I always remember that as a kid.  

Steve: Yep, exactly right! Yeah, Quaker had a terrific history here in Chicago and obviously in the Midwest as well. And Quaker is still part of Pepsi, you can get your Quaker products, including Gatorade and others still being sold.  

CJ: That's awesome! And for our listeners, the reason we are really excited, it sounds like we could have multiple episodes with Steve and all of his experience in different areas, but what we wanted to focus on today a little bit was his current role. And he even mentioned it, Steve, you mentioned that compliance wasn't even, you know, it's a relatively young profession, right?  

Steve: That is correct.  

CJ: And so, you don't go to school to become a compliance officer. But maybe now you do. Maybe now you can. So, can you just tell us a little bit about the program there at Loyola? What kind of people take, you know, who's it designed for and what's the length? Are there different levels? Tell us a little bit about the program there.  

Steve: That's a terrific question, CJ. And yes, now you can go to school to become a compliance officer or an ethics and compliance officer if that's something that you're interested in. It's an industry and a field that really has become more of a discrete field or discrete discipline, I should say, over the last 10 years. It really, has been around since the mid-90s, and boy it's really grown in the last, last few.  

So, Loyola is one of several law schools in the United States that offers various compliance tracks and I'll talk about Loyola's, which I think is the best in the country, but I'm biased. But CJ, to your point and it's a great point, there are different programs for different levels and different interest areas.  

The first of which is we do have a program for a master's in jurisprudence which is an MJ. Somebody that does not have a law degree decides, "Gee, I'd really like to go on and advance my career, or I'm interested in compliance. How do I do that?" and we have, you know, people that are directors in companies or managers in companies, paralegals, others who may look at it and say, "I want to have more knowledge, but I don't want to necessarily get a law degree." And so that's a two-year program, you need to do a thesis or a capstone at the end. Terrific background. I could tell you many of the students that have been at Loyola now for three years, have really benefited from it and have moved up in their organizations and I know a few that either have become or are on the step of becoming a chief compliance officer, which, by the way, CJ to your question and it was a really good one– You no longer need to be a lawyer to be a chief compliance officer.  

CJ: Right!  

Steve: Matter of fact, the industry is kind of moving, maybe not away from that, but you see that's not always the rule. The second group that we have is for the JD students themselves. So, Loyola has a couple of different programs for JDs, obviously, full time and then they have weekend student programs. So, you want to come in and you want to become a lawyer and you want to sit for the bar, that's the JD program. Well, you could come in and you can get a, we don't provide the certificates, but we provide the opportunity after you go through our program to sit for a certificate through one of the different groups like the SCCE Corporate Compliance Board, the CCB, is our accreditor.  

CJ: Right!  

Steve: So, you go in and you make that test afterward. We have a good number of JD students who do that as well as taking the bar exam so that you get the CCEP credentials after you do that. 

And then the final group is the LLM program. The LLM is an advanced degree for somebody who's got the underlying law degree, got the underlying JD degree, and that's a two-year program. It's probably, I would think little more discipline and certainly a little more in-depth than the MJ program. My wife, who is now the president and actually general counsel of the Shirley Ryan Abilitylab, she's a graduate of the LLM program here in Loyola and it's one terrific, terrific program. It really, I think really helps people that have an interest in different focus areas including compliance, enterprise risk management, and healthcare, we have a healthcare law, LLM and it's done really, really well, not only in Chicago but nationwide. So, that's the other part of the program too. So, they're really kind of three tracks, if you will.  

CJ: Yeah, and that's great background information because, Steve, you know, our listeners, predominantly healthcare folks, but you know some are lawyers and as you said, that's why I always ask the question at the beginning, how do you end up in compliance? Because people end up in compliance, especially in healthcare from many different paths, I come from a clinical background.  

Steve: Right!  

CJ: You have people who come from like, accounting and auditing backgrounds. We have people from law, we have, you know, so you have all these different backgrounds and that's why I think these types of programs that you've described, of course, the two that you described for those who want the formal legal track is wonderful. And it sounds like the MJ might be a good option for people who are really interested in compliance and but maybe they don't want to do that full legal route. Let me ask, is that MJ? Is that an in-person type of program? Tell us a little bit more about that. I think you said two years and what are the mechanics of it?  

Steve: Yeah, that's a great question. Our program is primarily online. We do offer a few classes for folks that are in Chicagoland or in town. I could tell you that there's an in-person compliance class for the JD student. But we're basically online for the MJ and the LLM program, which is been to me, it's worked out really well. Obviously, the pandemic brought the whole idea of online programming into the light, but boy, it's really where a lot of adult education is moving towards gives a lot of flexibility. Classes are usually, I mean on a logistic level, classic classes are usually in the evening, an hour, hour and a half, and also you'll have the asynchronous classes where the teachers and professors will record a lecture and then post various materials, and I can tell you I've watched a lot of them from various professors that we have here at Loyola and terrific material, and I and I really the students that I've talked to have been very pleased with how in-depth and the availability of the program.  

So yeah, I mean I would say, to your original point on all of this, it's amazing how, particularly in the healthcare world, people move about in different roles in different areas. Gone are the days, CJ, when I started where a person started and now, they were on a partnership track and that's all they did, they work for one firm. Now. I have people moving and with a good reason. I mean, I think the best leaders you see are really problem solvers and we really do pride ourselves on having a practical outlook. We really try to people to help train people, to become leaders in whatever roles that they might be in.  

CJ: Oh, that's so great. Steve, we're going to take a short break and to our listeners, we'll be right back in a moment.  

Welcome back, everybody from our break. I'm here with Steve Naughton, who got a great background, legal background, and compliance background and now is in the formal education of compliance. And we thought this would be a great topic because so many of our listeners are maybe just discovering compliance and they love it and they want to further their career and get more formal recognition for training and education. And Steve shared with us a little bit about kind of the legal routes and we're focusing a little bit on the MJ, the Masters of Jurisprudence, I think he said. And see if I could dive a little deeper into that program. Tell us a little bit about like the class size, what is the background like? Our listeners, they're thinking, "Oh, do I even? This is South law school. I'm not. I'm a nurse. I'm a, you know, I'm a medical coder. I'm this, I'm that, is that for me?" I mean, tell us a little bit about what the requirements are to get in, you know, what's the rigor, you know, and a little bit of the background of the cohorts or however it might work.  

Steve: Sure, that's another great question. And I should say just by way of background, CJ, that the MJ, the Masters of Jurisprudence, is also known by other schools as an MLS, Masters of legal studies, so you'll see it both ways. You'll see it, MJ and MLS. I think that Loyola probably is in the minority with an MJ, just so that there's no confusion, somebody sees it and what are they trying to do? So, they're the same thing and the same program. And so, for our program, and I think for the vast majority of other programs, it's 30 hours. You need to graduate in 30 hours, which are taken, like I said, over the course of a couple of years.  

And as far as what do you need? What is the requirement? you need to have a bachelor's degree, I have not seen any students come through the program or into the program in the three years that I've been in the program without a bachelor's degree in some form. We have students, by the way, that foreign students had a class last year that I actually had probably four or five students, a couple in Russia and a couple in Poland and Eastern Europe. So, we draw across the world, but our classes are generally, in probably the 15 to 25-student size, and most of them are under 20. As I said, you have to take a thesis or capstone to finish, which is your last year of studies, and you'd have one advisor assigned to you. You might have that class, for lack of a better term, have that advisor that the professor's working with one other person as well as you for the year that you have to go through your thesis or your capstone. It's basically primarily written work as far as what work is turned in. There are papers, a few professors still use exams, but not many. There are some groups of some professors who will use, you know, group assignments. I will tell you this, CJ, for those that might be aware of or familiar with MBA programs, it's not like an MBA program, where you're with the big group or you're with the team and you're working constantly. No, there are a few times that you're that you would be involved in that. We have classes offered in the fall, spring, and summer. So that people can take that and like I said, for the most part, evening classes. So, a lot of flexibility on them as far as the classes are concerned.  

I think we offer a total of about 40 classes overall; I'd have to go back and see exactly the number but obviously classes in basic compliance and healthcare enterprise and risk management. We started a couple of different classes. I teach a class now with the former chief compliance officer at Carnival Cruise Lines, Pete Anderson, and also the former chief compliance officer at CNH, Gwen Hassan. Gwen is kind of an expert in social issues relating to ESG, and Pete is an environmental attorney. So, we teach ESG. That's great. Been very popular. This is our second year teaching it. And Loyola very socially active school in the sense that, you know, it's the old Jesuit school wants to be; men and women for others. So, people really do like that and are able to use it in corporations and not just, "Oh, I have to go work for an NGO." So, we have a pretty broad curriculum and I can tell you we're very practically oriented, we really do try to help folks that come through the program as far as their network and as far as their career placement is concerned too.  

CJ: Oh, that's great. You mentioned about 40 classes, so does that mean there are like some core classes that everyone has to take? And then there are some electives or what's that kind of like?  

Steve: That's a great question and, yes, there are. We have core requirements, including if you come in for an MJ now, you'd have to take the initial compliance class, and you'd have to take an enterprise risk management class. You also have a class on legal writing and legal research, and then finally, you'd have a thesis class. So, I don't know what the breakdown is totally I think it's probably 12 hours of requirements ultimately with the remainder that you can take his electives.  

CJ: That's great. So as far as the type of students you've had that you would say are successful, so let's just, I'll just use myself as an example though my wife won't let me go to school anymore, I've already done too much! I got my MD and then I ended up, you know, working in compliance, and then I got a master's degree in education and if it were up to me, if I won the lottery, I would just be going to school full time and but so somebody like me that may have a like, maybe education and a clinical background, but you know, I never studied law, I mean, I read. And so, I do now as a compliance officer, right? But are there successful students coming from different backgrounds like them?  

Steve: Absolutely! That's absolutely right. We have a few MDs in our program. We have a healthcare program is called the Beasley Institute. It's always ranked very high in the US News and World Report rankings. I think last year they were two and I think they have a good number of doctors or MDs and nurses as well. So, you'll see healthcare professionals in various roles. I mean not just those with an MD or with a nursing degree, but you'll also see administrators, we can tell you right now I know of several that have come in and said, "Yeah, you know, I kind of know what compliance is about. I don't think I necessarily want to shift over to compliance," which a couple of them have. I could tell you that we have had a practicing physician or two who said, "You know what, this is what I really want to do. I want to move over into compliance," which is very interesting. But you know, when I say that, CJ, I think I may have given a little short shrift to ethics and compliance. And boy, when you start talking about the medical field, you can't forget about the ethics side of it. You would be a terrific candidate, and I would actively encourage your wife to allow you to do it. And if that maybe think thinking about teaching a class in the area, but bottom line is, yeah, in a lot of different areas, I've also seen a few salespeople in the pharmaceutical area that have gotten involved in taking the classes and then on our LLM obviously have lawyers that practice in this area and actually last year one of my classes I had two setting chief compliance officers, which would imagine really raised the level of the conversation and the discussion. So yeah, a wide range. But I want to actively encourage people that you're interested in, and I would encourage you, not just Loyola, there are a lot of really good programs across the country offering different things, but I can tell you this, Loyal really does have a great healthcare program that's part of this compliance program.  

CJ: Well, and I was just going to that was going to be my next point, it sounds really interesting because you have kind of these core foundational classes and then you allow individuals to take electives and at law schools that have such robust healthcare programs, like Loyola, you know I'm making this up and you can correct me, but it sounds like you could probably take a class on HIPAA or a class on the False Claims Act or class on these laws, you know, Anti-kickback Statute or the Stark law, it sounds like you could dive deep into some of those laws after these foundational classes, is that accurate?  

Steve: Oh, that's absolutely accurate. And you hit upon three or four that we have specific classes on. I could tell you we have healthcare and privacy. We certainly have the Anti-kickback. We've got a class for example on FCPA, which is not purely healthcare. But boy, on the healthcare side, you're right. I probably should have a better litany, but I'll provide it to you when we have finalized the website that people can look at it and see what exactly what we have, but that we have a broad range in the healthcare area for sure.  

CJ: Yeah, that would be great. And we'll give you that opportunity to make some links if that's easy for you to do and we can put those in the show notes. And you mentioned the FCPA, so you know, I also after working for hospitals and doctors, I became the chief compliance officer for an international medical device company, and FCPA, the Foreign Corrupt Practices Act, it's a big, big deal in those industries, pharmaceutical, and medical device because in most of the world, doctors and nurses work for state-run organizations or country run healthcare systems and under the FCPA, at least at the time when I was working in that area, they met the definition of a foreign official. So, foreign officials are not always the department, you know, the Minister of the Health Department for a country, it can also be doctors who worked for a National Health system. And so just these nuances of the law and then you get these unique scenarios that sound like I said I want to enroll!  

Steve: Sounds like you want to go back and be a chief compliance officer and I would say to you that we do see individuals for exactly the scenario you laid out that, "Gee, I'm interested in doing something that's a little more international. I work at some Healthcare Group or something along those lines," and you'll see people say, "No, I'm interested in or I'd like to do something a little more international," and this is actually, compliance is a way that I've seen people get that international take on it. The FCPA is obviously one of the issues that you'd have to face.  

CJ: Yeah, exactly! Well, we're getting a little close to the end of our time. I want to ask you about one thing you mentioned about job placement and then I'm going to give you a moment to, you know, tell us anything else that I might not have asked you about. But could I ask you about job placement? You mentioned it. I'm just curious about how you know you're helping students and if you have any anecdotes that you can maybe share.  

Steve: No. Loyola, first of all, does a terrific job with its outplacement program and with its career placement office at a formal level. But really informally I can I could tell you this on a couple of different levels. We really do try to help people that come in and students that come, network and you know I'm a graduate, as I've noted from Notre Dame, I would love to have a model and have the school modeled after the alumni system and the alumni network of Notre Dame and how well they help each other. But the professors and the adjuncts we talked about have been just terrific in helping people as they look out and as they either kind of look for career counseling. You obviously would have an advisor and the advisors are top-notch, but even more on an informal level, and I won't mention any names because I'll leave people out, but what a really terrific opportunity people have had by talking to some of our adjuncts, who will, you know, kind of either set them in another direction or help them with contacts, you know, I don't have the statistics in front of me, but I can tell you that we place very well and that people that are in sitting compliance jobs have used this. They have parlayed this into helping them to get promotions, which I'm very proud to see.  

CJ: Yeah, that's so great. Just I think the fact of being a student with these other students who are coming from varied backgrounds, you know, you're already networking just by being a student, and you know, working with other students in your class and you mentioned, right, you have a chief compliance officer in your class, you know, they might have openings, you never know!  

Steve: Exactly right!  

CJ: Well, Steve, we're getting to the end, I could talk to you all day. What did I leave out? What other things? Do you have of interest, if any, as we get ready to close in a minute or two here?  

Steve: Well, all I would say, CJ, is that I would encourage anybody who is listening to this podcast if you're interested in this area if you're interested in continuing, please reach out to me or reach out to somebody at Loyola, or they're like I said, the other schools, I really do look at this as a time when, you know, these areas are growing so quickly in different routes and we really do need people that are really actually curious and even, to kind of a technical side, trained in the area to help us in the leadership in the future because compliance I think is going to be really at the forefront of a lot of cutting-edge issues. We haven't talked about AI or things like that, but boy, you can see how things are going to change very quickly now.  

CJ: And I agree with you, it's like the skill set for a compliance officer it's a little different. You have excellent attorneys who become compliance officers, but not every good attorney is going to be a good compliance officer because it's not just interpreting the law. And of course, compliance professionals are always interacting with the legal departments, for their expertise and help. But a lot of it is, you know, operations, it's management, it's relationship building and you mentioned risk assessment and those sorts of things. And those are really important.  

Steve: And we are seeing more and more people use, either a legal degree to a certain extent or even these compliance specializations that are moving over and maybe they weren't in the operation side or the business side. I see it now really as viewed as a plus, used to be when I started, boy, if you were a JD, you were too conservative. You were too slow and they didn't want you on the business side. I don't think that's the case anymore. As a matter of fact, I think with some organizations it's viewed as a plus.  

CJ: And especially in very, very regulated industries, right where that understanding is a part of the strategic vision of the direction the organization is going to go in.  

Steve: Right!  

CJ: So, you know, you have to understand the compliance nuances and maybe what the expense might be if you're going to branch off into Europe, understanding what GDPR is, and you know those privacy laws, that has an added financial burden. And it's not just branching out into that area and think there's nothing else to think about that you got to have compliance people at the table when you're doing strategic vision planning for the organization.  

Steve: Absolutely agree!  

CJ: Steve, is there a website, we can put in the show notes, but is it easy to say verbally for people if they're interested in? Is it Loyola Law or what is it?  

Steve: You know what, I will provide that to you, CJ, and then I'll get back cause I actually was looking at it and I had the wrong one when I gave it to somebody last week. So, I will get to the right one and perhaps we can have you just put that in at the end of this. We'll do that.  

CJ: So, to our listeners, we'll include these types of details in the show notes. I know that I have Googled Loyola Law School, and I remember it's in Chicago. There are a couple of Loyolas around. And I've met some wonderful people at conferences who've worked with the university there and so. Anyway, Steve, thank you so much for sharing kind of this, this area of compliance and professional preparedness that didn't probably exist 10 or 15 years ago, I don't know.  

Steve: CJ, you're welcome. I really enjoyed the conversation and the discussion, and I wish you well with your podcast. It's really, really terrific.  

CJ: Thank you! And thank you to all our listeners for listening to another episode. If you like these episodes, please hit the like button and share with colleagues. That's the one way that we can get the word out on this. And as always, if you have ideas of guests that you'd like to have on the podcast, or if you know people, don't be shy, you can reach out to me or reach out to the folks at healthicity, and we'll get them on the show at some point, cause we want to provide what is important to you. So, thanks everybody, and have a great and safe day.  

Steve: Thank you, CJ!

Questions or Comments?