With global regulators cooperating like never before and with record fines being levied against companies for noncompliant practices, there has never been a better time to revisit and discuss how companies organize themselves to mitigate risk.
Companies are increasingly bifurcating their risk programs by delegating all matters of legal risk to their general counsel, while directing their chief compliance officers to address questions of organizational risk. On the outside, this sounds reasonable. But there are a number of problems that arise from dividing up the responsibility for risk management.
