So, just before Easter, in 1957, a little book you may have heard of, calledThe Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name "Dr. Suess" — later said that of all his children's books, he was proudest of this one, because "it had something to do with the death of the Dick and Jane primers," which he thought would bore any child to tears. In honor of this occasion, here are a few "fun facts" about the book that has taught millions of children how to read:
- Geisel was given a word list by his publisher and told that he needed to work them into his book. He was so frustrated with this approach that he decided to scan the list and instead create a story based on the first two words he saw that rhymed, which were "cat" and "hat."
- The Cat in the Hathas been translated into 12 languages, including Latin, where it bears the title "Cattus Petasatus."
- In 1999, the U.S. Postal Service issued a stamp featuring the Cat in the Hat.
- The NY Public Library's list of "Top 10 Checkouts of All Time" showsThe Cat in the Hatas number 2. But we imagine it would be ranked number 1 if Dr. Suess had stuck with his original text, which was titled ...
The Non-Compliant Cat in the Hat
Work was all dreary, meetings set for all day,
As we reviewed Outlook, grayed out all the way.
I sat there with Sally, we sat there, we two.
And I said, "How I wish we had something better to
do!"
But with meetings and Zoom all we could do was to
Sit!
Sit!
Sit!
Sit!
And these interns did not like it, not one little bit.
And then ... something went BUMP!
How that bump made us jump!
We looked! And what we saw was better than our Slack chat!
We looked! And we saw him! The Non-Compliant Cat in a Hat!
The hat was all crazy, it had slogans galore!
That made fun of our procedures, and said "Compliance's a
snore!"
And "internal controls, are great, for do-nothing
bores!"
And "training is worse than fourteen bedsores!"
And he threw the door aside, it clanged with a bang,
In strutted a Cat with that hat that just sang!
"Hello, my dear interns! Why so glum and so sad?
I've come to bring fun, let's make this less
drab!"
Sally looked at the Cat with a skeptical stare,
"Who are you, and what's with that hat and that
hair?"
"Oh, I'm the Cat, and I'm here to have fun!
Forget all the rules; let's get this day done!"
But just then, from a bowl on the corner desk bright,
Swam a Fish in a bowl, trying to bring compliance to light.
"Please listen to me! Don't let chaos unfold!
The rules are important, their value is gold!"
But the Cat just laughed, waving a paw in the air,
"Who's heard of a CCO Fish? And why should we
care?"
There's so many fun things, let's send out this
contract,
To send goods to Iran, we won't tell OFAC!"
"Compliance screening, well we'll steer clear of
that,
And play a good game, it's called 'Let's Ship It
Fast!'
We'll send our great goods, to any place that will buy
—
Even to Iran, where demand's flying high!"
The Fish started gasping: "You'd cause us much
pain,
Such shipping's forbidden, compliance down the drain!
Sanctions and penalties, fines and disgrace,
If we follow your tricks, it's jail we'd face!
Hey! You two interns, can't you see what's at stake?
If you follow this Cat, big trouble you'll wake!"
"Oh, Fishy, relax! You're such a drag,
All you care about is waving the compliance flag!
If you're so scared of OFAC, let's play 'Let's
Bribe with a Fish,'
In some places, it's harmless, and really delish!"
But the Fish would not have it, his voice was quite stern,
"Now, Cat, that's a violation, and work we should
spurn!
Anti-corruption rules are clear, offering fishy quid pro quo,
Could cause us all trouble, if about it we know!
And what do you mean, when you say 'its delish?'
I especially dislike bribes that involve eating this
Fish!"
"Have no fear!" said the Cat, "there's so
much we can do!
If we are not stuck in the compliance glue!
Let's skip the audits! Who needs those old things?
And trade secrets? Hacking's fun, let's see what that
brings!
Who needs policies, forms, and approvals galore?
I'll say it again, compliance's a bore!"
And the Cat, then he said, "silly Fish, don't be mad
—
I just want to show them some fun to be had!
How about a game? We'll call it 'Price Fixing
Fun!'
We'll chat with competitors to help everyone!
How silly it is, to keep our prices so low,
When a chat or a call could make profits grow!"
But the Fish swam around in his bowl, oh so fast,
This new game made the CCO Fish quite aghast!
"Antitrust law says 'No way! Conspiring's forbidden
today!'
You will all land in jail, price fixing's illegal per
se!"
So, Cat, take your tricks to some other place!
Your understanding of compliance is very off-base!"
But the Cat was undeterred, by our compliance construct,
As he hopped and he jumped onto our Code of Conduct.
"Look at me! Look at me! Look at me NOW!
Non-compliance is fun, but you have to know how!"
"I can ship controlled goods, use a license that's
fake,
Waiting for BIS, that would make my mind ache!
I can cook these books! Hide agents all on the take!
Accounting accuracy is for nerdy fruit cakes!"
"From your Code of Conduct, I can jump on this desk!
Your mindless compliance, I find quite grotesque!
I can bribe with aplomb, the hot line I'll finesse!
But that is not all. Oh, no. That is not all, I guess
...."
That is what the Cat said ... then he fell on his head!
Knocking off his hat, on the Code of Conduct he went!
He knocked down the Fish, who fell into a pot!
Who said, "Would HR approve Fish assault, no they would
not!"
"Now look what you did," said the Fish to the
Cat.
"Our compliance's a mess, we'll never get it
back!
You've bribed everyone, conspired to fix prices, too!
Shipped goods to Iran, flushed our controls down the
loo!"
You SHOULD NOT be here, undermining our compliance, so true,
It helps us control risk and makes sure fines don't
accrue!"
"You've crossed too many lines!" cried the Fish
with despair,
"Of our published red flags, you were never aware!
The auditors are coming, and they won't be so nice!
You followed no rules, now you'll pay a great price!"
"But I like to be here. Oh, I like it a lot!"
Said the Cat who loves hats, to the Fish in the pot.
"I will NOT go away. I do NOT wish to go!
And so," said the Cat, "so, so, so ...."
"I will show you another good game that I know!"
And then he ran out, he practically flew,
Then he came back, with compliance gurus!
"Now look at this trick," said the Cat, with a
grin,
Let's play one last game, called 'Comply and We
Win!'"
"The compliance gurus, named Risk One and Risk Two,
Know compliance failures are things that could bite you.
These compliance gurus, with their suits oh-so-neat,
For controlling risk, their controls can't be beat!"
And Sally and I, did not know what to do.
So we had to shake hands, with Risk One and Risk Two.
But CCO Fish said, "No! No! Those gurus, please make them
flee,
Risk is managed through our controls, and should always
be!"
"Have no fear, little Fish," said the Cat with the
Hat.
"Let Risk One and Risk Two work," and he gave them a
pat.
"You will see they will say, what I did was not bad,
Sure I skirted some rules, but you'll see they're not
mad!"
But what they next said, turned the Cat's words right on
their head,
As they surveyed the damage, they put his non-compliance to
bed!
"You see," said Risk One, "This Cat's right out
of line!
No checks, no controls, compliance far from divine!"
And Risk Two added, "This Cat needs training, that much is
clear!
Policies are great, but only if everyone adheres!"
The Cat looked remorseful, his fun now all gone,
And he stared at his Hat, that started the non-compliance
run.
He took a deep breath, as realization it dawned,
That controlling risk, is everyone's bond.
"Let's fix all the chaos, I now see what I've
done,
It never works out, doing compliance end runs!"
Then the CCO Fish said, "Look! Look!" And our Fish
shook with fear,
"The auditors are coming! They are on their way here!
Oh, what will they do to us? What will they say?
Oh, they will not like finding compliance circumvented this
way!"
"So, DO something! Fast!" said the Fish. "Do you
hear!
I saw them. The auditors! The auditors are near!
So, as fast as you can, think of something to do!
Do your best, Risk One and Risk Two! Show you're compliance
gurus!"
So Risk One and Risk Two, moved at a fast pace,
To reassert compliance, from last to first place!
"You can't ship to Iran!" Risk One said with a
frown,
"That's OFAC's rule, so let's break it all
down."
Risk Two wagged a finger, "No bribing with fish!
With or without lemon, let's cancel that wish!"
They sorted each paper, they checked every box,
They tightened procedures, secured every lock.
"Compliance," they chanted, "is here to stay!
We'll make sure this company acts the right way!"
Then Risk One and Risk Two, well they dragged out the bad
Cat,
Who barely managed to first grab his sad hat.
Then the auditors came in, and they said to us two,
"Did you work very hard? Tell me. What did you do?
Did you follow our controls, compliance earning all plaudits,
What will we find, if we do a quick audit?"
And Sally and I did not know, what to say, what to do.
Should we tell the things, that today we did do?
Should we tell them about it? Now, what SHOULD we do?
Well ... what would YOU do, if the auditors asked YOU?
If you have questions about this topic, please feel free to reach out to Dr. HuSuessisan or your Foley & Lardner attorney. If you would like to see future updates regarding "What Every Multinational Company Needs to Know" about operating in today's complicated international trade world, please sign up for our Tariff & International Trade blog — click here to register.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
