Karen Griffin Brings an Engineering Mindset to Compliance

As Mastercard’s chief compliance officer, Karen Griffin tackles compliance with out-of-the-box thinking and novel methodology

Karen Griffin would like you to think about your skill set—more specifically, how it might be applied to something outside of your comfort zone. It’s an exercise that the executive vice president and chief compliance officer at Mastercard has employed often over the years, and it helped get her where she is today. At a former company, a new head of HR wanted to make sure employees with the right skills would be identified to fill critical new job openings and created a massive global database that would match skills to open positions. Griffin, then a supply chain director, was asked to interview for an executive compliance position—an area where she had no previous experience.

Karen Griffin Mastercard
Photo by Heidy McIntyre

“I thought someone else should be interviewing for this role,” Griffin remembers. “But I went home and talked with my husband about it and he said I should take the interviews and just have fun with it.”

Through a progression of interviews, Griffin realized that the general counsel was seeking a businessperson for the compliance role: someone who understood how work was done, how policies were executed, and who had personally been affected by the policies and procedures the compliance team put in place. She began to think she might have the skills for the job. Not only was she correct, but more than fifteen years later, she’s still working in compliance.

That’s how a mechanical engineer became the chief compliance officer for one of the top financial services organizations in the world—and Griffin encourages others to step outside of their comfort zones as well. “Don’t box yourself in, thinking that your education and the experience that you have only fit into a very narrow set of opportunities,” she says. “Knock down those walls, take stock of your skills, and you will quickly see that they can be directly transferable into numerous other roles. Then go for it.”

Griffin has moved from straight engineering roles into business leadership roles that give her a unique vantage point. “I have found over the years that these experiences have proven to be invaluable in my compliance journey, in how I designed and implemented controls that the business can execute, because I have a sense of what would work and what wouldn’t,” Griffin explains. “I’m able to see how you would actually look to embed compliance requirements into existing business processes, so employees can just continue to work through one process that is streamlined and simplified.”

An Exercise in Compliance

Karen Griffin brings her creative approach to compliance training, among other things. For one area of training, Griffin engaged Richard Bistrong, a former international sales executive who served fourteen months in a United States Federal Penitentiary in Lewisburg, Pennsylvania, after pleading guilty to violating the Foreign Corrupt Practices Act in 2010. By enlisting Bistrong to share his journey, Mastercard created storytelling-based modules in memorable training that Griffin says has helped engage employees around the world.

Over the course of her career, Griffin has seen virtually all phases of the product life cycle. She led product engineering and customer loyalty with international clients. She also served as the global head of quality, led customer delivery operations and held numerous leadership positions within the supply chain. By applying engineering principles to the otherwise legal compliance framework, Griffin has approached the traditional compliance practice in a completely different way.

Griffin’s past experience has influenced Mastercard’s innovative compliance system. “We want to make sure that the compliance outcomes we desire are embedded into processes, with measurements and testing of controls,” Griffin explains. “By applying engineering principles of data-driven feedback loops and failure mode analysis, we drive transparency, accountability, and continuous improvement.” Mastercard’s compliance team utilizes advanced data analytics, AI, and bots to validate the effectiveness of the control environment. Griffin says, this ensures the reliance on facts and data in managing the compliance system.

The building of easy access to key compliance metrics in close to real-time provides another layer of assurance. “We quickly realized that these metrics that we have made available to the compliance team, are also very useful to other internal control functions,” Griffin says. “So we make them available to those folks as well. And it’s basically available with the touch of a finger.”

Griffin has also paid close attention to the make-up of Mastercard’s compliance team. “I’ve been laser-focused on ensuring that our compliance function has a diversity of experiences on the team,” she explains. “This means ensuring that we have critically important lawyers and compliance professionals, but I have also augmented the skills on the compliance team with business professionals.” Griffin’s team also includes data analysts, data scientist, and technologists.

“It was very important for me to bring these folks together, because I have seen firsthand that having a rich set of talent with diversity of thought and experience really helps eliminate blind spots when building out key elements of the compliance system and executing robust monitoring and testing programs,” Griffin says. “I’m so proud of the talented team we have here at Mastercard, and I’m just honored to work alongside these remarkable colleagues every single day.”


Under the leadership of Karen Griffin, along with the creative directorship of the Cohn Creative Group, real-world ethics and compliance training videos are now available to multinationals on a global basis, in partnership with my consultancy, Front-Line Anti-Bribery LLC. Corporations can now request evaluation access to both award winning training videos, Behind the Bribe: The Richard Bistrong Story and From Beach House to Blackmail, by the “Request Free Demo” link here. Thanks to Karen’s background, experience and perspective, “tick-the-box” compliance training has now been transformed into content that is both relatable, as well as designed to engage and inspire teams on a global basis through compelling storytelling. Now more than ever, during this time of crisis, making sure that ethical culture remains strong has never been more important. Through this inspiring partnership with Karen and her Mastercard team, we can use innovative content, that’s easily delivered, to make sure that social distancing isn’t integrity distancing. –Richard Bistrong, CEO, Front-Line Anti-Bribery LLC