The Excitement of Creating Precedents: Proactive Business Compliance that Contributes to the Company’s Success

The Professionals series showcases talented experts who support PayPay Group’s operations.
This time, we interviewed three members of the Legal & Compliance Division. We explored the background behind the establishment of the Business Compliance Team, why they are ahead of the industry and what they find exciting about their work.

Is Compliance a Hindrance to Business?

What role does compliance play and what challenges does it encounter?

Suzuki:
When it comes to compliance, especially at financial institutions, it is often associated with monitoring adherence to laws, regulations, and internal rules, pointing out violations, etc. This can sometimes create the perception that compliance hinders business operations.

However, as evidenced by the fact that it is established within the same company, the Compliance Department is not an enemy of the first line, but rather an ally. It plays a role in ensuring that there are no shortcomings that hinder the promotion of corporate growth and the expansion/enhancement of services and, if necessary, rectifying such shortcomings.

While the first line is responsible for sales activities, feature development and improvement, and other actions that contribute to profitability directly, the second line is expected to support and provide a different perspective and standpoint, engaging in activities that complement the first line’s efforts.

Formation of the Business Compliance Team (“BizCom” for short)

Suzuki:
In November 2022, the Legal & Compliance Department was divided into the Legal Department and the Compliance Department, and a new Business Compliance Team was further established within the Compliance Department. This organizational structure is designed to clarify that the Compliance Department is not a distant department from the first line business, but rather exists to assist in a closer position.

Is Business Compliance commonly found in other companies in the same industry?

Suzuki:
Ethics compliance and business compliance are not uncommon in foreign countries, but in Japan, especially in FinTech companies, legal compliance is the norm, so ethics and business compliance are still rare in other Japanese companies. We are working towards becoming the number one FinTech company and taking the lead in the industry. Currently, we have a team of seven members dedicated to business compliance.

Business Compliance is a Proactive Compliance that Aligns with the First Line

Why are you all working for PayPay in the first place?

Isobe:
I was attracted to the breadth of the business while working on the financial licensing of PayPay during my time at SoftBank Corporation. The ability to communicate and collaborate with business divisions, discussing ideas like “What if we do this?” or “Let’s try it this way,” was highly enjoyable. I wanted to continue that experience, and that’s why I’m here. Currently, I am the leader of the newly established Business Compliance Team.

Kuwabara:
In my case, after joining PayPay, I had actually moved to another company to experience a smaller scale business, but I was able to find a connection again and came back to work here. I think the good thing about PayPay is that we can do big things that have an impact on society with a sense of speed. I currently serve as the head of the Compliance Department.

What specific tasks are carried out in compliance?

Suzuki:
While maintaining and managing business licenses, which is the fundamental premise of our business, (“defensive compliance”), we also focus on “proactive/offensive compliance” by collaborating with various departments in the company to check and support the development of new business ventures and services. We aim to create services that not only comply with regulations but are also loved by our users.

Above all, internal communication is crucial. To work closely with the first line, it is essential to have a deep understanding of our services, objectives and challenges of each department involved in creating those services, and the expectations and demands of our customers.

What have been your most recent initiatives since Business Compliance Team was established?

Kuwabara:
Based on the aims and expected roles of the team, we started by creating a team structure and raising awareness of its purpose. We believe it is important to adapt our mindsets together through daily communication such as team meetings and one-on-ones with team members.

Isobe:
Many ideas are born every day in the company. We often consult with the first line teams about various project ideas, asking questions like “Can we do something like this?” Instead of giving conventional feedback, we collaborate with the first line teams to think, “How can we advance the project and turn this into a successful service?”. We also involve the expertise of the second line and brainstorm together. As a result, we are able to deliver good services promptly. We work on this every day to accelerate the process.

What are the challenges you face as practitioners in the field, and what do you want to strengthen in the future?

Isobe:

1. Understand our services.
2. Obtain the background and purpose of the project.
3. Imagine the reaction of customers (general public, outside of the company)

If we can truly implement these aspects and ensure collaboration not only within first line teams but also across different lines, we can achieve better results. Without knowing the background of the service and business, it is impossible to persuasively explain or make proposals to the first line. Not only that, but we must also imagine the public reaction upon release. If we can do this, we will be able to fulfill the role of Business Compliance, supporting the first line in advancing the business.

Suzuki:
It’s important that we don’t impose our theoretical solutions when there are problems. Understanding what the first line employees are thinking, what challenges they are facing, and what they want to achieve is crucial. We need to think of ways we can support this. While it’s common to refer to the first line employees as “compliance customers,” I don’t see it that way. They are not customers but colleagues. We believe that since we are colleagues in the same company, we should work towards the same goal and solve problems together.

Isobe:
I am keenly aware of the importance of internal communication that Suzuki-san mentioned, in order to understand the background of the business and the customers beyond it, as well as to strengthen cooperation with the first line.

Enjoying Compliance

What aspects of PayPay’s 5 senses are important to you?

Kuwabara:
We place great importance on communication and not compromising as professionals. These two aspects are especially important. PayPay’s services are developed in collaboration with many colleagues in the Business and Product Divisions, as well as other second line divisions, so communication is the foundation.

We don’t adopt a mindset like, “This is a minor concern, but it’s okay.” Instead, we thoroughly consider any concerns, even going back to the purpose of the law and regulations. We focus on understanding what we cannot do and how we can achieve it.

Isobe:
Each department will have a slightly different emphasis on different values, but I believe it’s important to have all five senses. Professionalism is a prerequisite, and among those, the most important aspect is communication.

Suzuki:
I believe the people who will be successful at PayPay are those who can reflect on the five senses and constantly look back on themselves.

What is the atmosphere of the current team?

Isobe:
Our members come from a variety of backgrounds, and they implement business compliance, which requires a comprehensive perspective. While each person is responsible for their project, communication within the team is important to accumulate knowledge and share perspectives. Therefore, we speak honestly with each other without considering positions, roles, or tenure at the company. We are especially conscious of maintaining an atmosphere where people can work with a smile as well as a sense of urgency.

Suzuki:
Kuwabara-san and Isobe-san are particularly kind individuals. I believe it’s because of them that we were able to establish the Business Compliance Team! The consideration and communication towards team members are not very compliance-like, in a good way. I believe that these everyday relationships contribute to credibility in important situations.

Kuwabara:
Do you really think so?

Suzuki:
I don’t usually say it, but I wanted to take this opportunity to tell you! (laughs).

What is the best part of working with your team?

Isobe:
The best part of this job is that I am directly involved with the frontlines departments that plan the business, and actively contribute to the realization of service proposals at the discussion stage. When PayPay services I’ve been involved in are released and I see the reactions from users, I feel a sense of accomplishment in my work along with the weight of responsibility.

Suzuki:
When our team members participated in significant projects, we would receive messages like “It’s been released! It’s always exciting when the projects we worked on go live, ” or when there were issues, the messages we got would say “Uh-oh” (laughs). PayPay’s compliance team gets deeply involved in projects, so when a project we worked on is released or when there is a problem, we feel a sense of joy or responsibility as if it were our own. One of the advantages of being part of BizCom is that we can work independently on what we enjoy without being too bound by past experiences or tenure.

Kuwabara:
One thing that is appealing is that through our projects we get to interact with many different people and ideas, which expands my perspective and knowledge. It allows me to grow as a person daily.

What would you like to accomplish or try in the future?

Kuwabara:
It’s all about “Enjoying Compliance.” Even if there are compliance hurdles, it’s not simply a matter of saying “No.” It’s interesting to think about how we can overcome them, such as considering “Can we do it this way?” or “Is this the interpretation of the law?”. I want to make an organization where people can enjoy thinking for themselves and actively propose solutions.

Isobe:
I want to build the Business Compliance Team into a highly contributing one that can explain both internally and externally that we have appropriate controls in place, even as our services and company size grow rapidly and the environment changes quickly.

Suzuki:
I want to change the state of compliance in Japan. When we think of compliance, we have an image of a group of specialists who are distant from the business and are bound by rules, obligations, and precedents. In a large company with a long history, there tend to be established answers based on precedents, but here at PayPay, because the industry and the company are both young, we can create our own answers while catching up on a wide range of knowledge. I want to create an organization that can contribute to the business by taking advantage of an environment in which people can express their opinions regardless of seniority.

*Recruitment status and employee affiliations are correct at the time of the interview.