The Grinch Who Stole Compliance
A Publication in Foley鈥檚 International Trade, Enforcement & Compliance regulatory series.

Happy Holidays! We are hoping that everyone has gotten in all those last-minute CLE credits and finished holiday shopping for that special someone who is looking for compliance training aids under the Christmas tree. And for anyone who is wondering which of the classic holiday specials to watch, our suggestion is to watch the one that provides the most compliance-related learning. We mean, of course, that you should watch . . .
The Grinch Who Stole Compliance
Every Who down in Workville liked Compliance a lot . . .
But the Grinch, who toiled from his home office, did NOT!
The Grinch hated Compliance! In every season!
Now, please don鈥檛 ask why. No one quite knows the reason.
It could be his morals weren鈥檛 screwed on just right.
It could be, perhaps, his shoes were too tight.
But I think that the most likely reason of all,
May have been his expense account was two sizes too small.
Whatever the reason, his expense account or his shoes,
He stood there dreading Compliance Week, hating the Whos.
And most of all he hated the pretentious Compliance Whos!
Who saw compliance in black and white, and never chartreuse!
Staring down from his mancave with a sour, Grinchy frown,
At the warm lighted conference rooms below in their town.
For he knew every Compliance Who was planning a compliance review,
They were toiling away to prepare Compliance Week slides all anew!
And whether it was in person, or just over Zoom,
He knew that he would hate it all, and so very, very soon!
鈥淎nd they鈥檙e adding compliance cartoons!鈥 he snarled with a sneer,
鈥淎nd overusing PowerPoint effects! I can see it so clear!鈥
鈥淥ne slide is spinning, and the next one is morphing,鈥
鈥淚 couldn鈥檛 stand it again, not even with four shots of morphine!鈥
Then he growled, with his Grinch fingers nervously drumming,
鈥淚 MUST find some way to stop Compliance Week from coming!鈥
For tomorrow, he knew, all the Who women and men,
Would wake bright and early. For Compliance Week, they鈥檇 rush in!
Being late to Compliance Week, why that would be a sin!
For mini-bagels and compliance presentations, they wouldn鈥檛 just Zoom in!
鈥淚 MUST stop this Compliance Week from coming! But HOW?鈥
Then he got an idea! A non-compliant idea!
THE GRINCH GOT A WONDERFUL, NON-COMPLIANT IDEA!
鈥淚 know just what to do!鈥 The Grinch laughed in his throat.
And he made a quick Santy Claus hat and a coat.
Then the Grinch took his hastily built Santa sled down to the Workville Town Square,
And he entered Workville headquarters to begin his anti-Compliance Affair!
鈥淭his is stop number one,鈥 the old Grinchy Claus hissed,
And he entered the conference room with a non-compliant clenched fist.
鈥淭hese PowerPoints,鈥 he grinned, 鈥渁re the first things to go!鈥
And the small mini-bagels, and the compliance break cookies, were the next things he stowed.
And he went around the room and took the presentation projector!
And the mouse! And the speakers! And the HDMI connector!
And he stuffed them in bags. Then the Grinch, very nimbly,
Stuffed the bags up the never-before-seen chimney!
鈥淎nd NOW!鈥 grinned the Grinch, 鈥淚 will stuff up the conference room table!鈥
And the Grinch started to push, as hard as he was able.
When he heard a small sound, expressing concern.
It was the sound of a hard-working intern!
Little Cindy Lou Who, who was not even twenty-two.
Who had always dreamed of becoming a good corporate Who!
She stared at the Grinch and said, 鈥淪anty Claus, why?
Why are you taking our Compliance things? WHY?鈥
But, you know, that old Grinch was so smart and so slick,
He thought up a lie, and he thought it up quick!
鈥淲hy, my sweet little tot,鈥 the fake Santy Claus lied,
Using triggering language HR certainly would mind!
But the Grinch didn鈥檛 care, as he spun his great lie.
He smiled and said, 鈥淭hese things won鈥檛 access encrypted Wi-Fi.鈥
鈥淪o I鈥檓 taking them home to my workshop, my dear.
I鈥檒l fix it up there so you hear crystal-clear.鈥
And his fib fooled the intern, who鈥檇 watched too much Tok and the Tik.
So by the time he finished, she鈥檇 moved to the next topic!
Then the last thing he did was change the compliance quiz on the white board.
So it said if you stole from your boss you鈥檇 get a high score!
It was quarter past dawn . . . all the Whos were still dreaming,
Except Cindy Lou Who, who was internet meming.
And he left with all things, and even took their Compliance controls!
The Code of Conduct! The Policies! Their ESG goals!
Three thousand feet up! Up the side of Mt. Crumpit,
He rode with their compliance, planning to benchmark and dump it!
鈥淧ooh-pooh to the Whos!鈥 he was grinchishly humming.
鈥淭hey鈥檙e finding out now no Compliance Week鈥檚 coming!鈥
鈥淭hey鈥檙e just waking up! I know just what they鈥檒l do!鈥
Without their Compliance policies it will all go askew!
Not a single one will know what to do!
And the compliance problems, they will suddenly accrue!
Then he looked! What he saw was a shocking surprise!
Everyone still worked, in a compliant enterprise!
Every Who down in Workville was working! Without any controls, large or small.
But ethically! With no whistleblower concerns at all!
He HADN鈥橳 stopped Compliance Week from coming! IT CAME!
Somehow or other, workers worked just the same!
And the Grinch, with his grinch-feet ice-cold in the snow,
Stood puzzling and puzzling: 鈥淗ow could it be so?鈥
鈥淚t came with no training, no CLE credit!
No bagels or compliance quizzes from Compliance Askreddit!鈥
And he puzzled three hours, till his puzzler was sore.
Then the Grinch thought of something he hadn鈥檛 before!
鈥淢aybe Compliance,鈥 he thought, 鈥渄oesn鈥檛 come just from one training.鈥
鈥淢aybe Compliance . . . is long-term and self-sustaining!鈥
And what happened then? Well . . . in Workville they say,
That the Grinch鈥檚 compliance metrics grew three sizes that day!
And the minute compliance constraints didn鈥檛 feel quite so tight,
He brought back compliance through the bright morning light.
And he brought back the bagels and the HDMI connector!
And he personally hooked up the compliance projector!
And he, HE HIMSELF! The Grinch gave the Compliance Week speeches!
And that year there were no compliance lapses or breaches!
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