An Independent CCO is a Compliance Program Requirement

, Corporate Counsel


As prosecution risks have increased, so has the role of the chief compliance officer. Companies are fast recognizing the importance of elevating a CCO and protecting their independence.

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What's being said

  • A Compliance Attorney

    I am an in-house compliance attorney at a Fortune 100 company and I agree with "A Typical GC". Being in a a separate group within legal, compliance attorneys are integrated with our colleagues who counsel the business daily. We become aware of changes in the business that may create new compliance risks early and are able to proactively develop compliance programs and processes to mitigate. This would much harder - and may not happen at all - if we were separate. Our chief compliance officer, who reports to the GC, has regular independent access to the Audit Committee and we comply with the sentencing guidelines. The push from certain compliance professionals to create a separate C level function does not seem evidence based.

  • A Typical GC

    The parade of “compliance professionals” arguing that their profession needs to break out from under the constrictive confines of the GC has become offensive. Sure, it might make sense in a large company with substantial resources and a correspondingly substantial compliance program. But what about the vast majority of companies, small to mid-sized, where resource constraints are a daily challenge? Why do compliance professionals think that they are more important than, say, a safety officer in an industrial company? What data is there that proves the separation of compliance from legal leads to a better compliance culture?

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