A team of two - why GCs and chief compliance officers must work in tandem
The role of the chief compliance (and ethics) officer (CCO) is currently a hot, if confused topic. What does she do - ensure good process or enforce strict compliance? To whom does she report - general counsel/chief financial officer or to chief executive officer/board? What is her role in shaping the company's voluntary adoption of ethical standards beyond what the law requires? This issue has been thrust into high relief by regulators and enforcers who, in light of various scandals, want a more independent compliance function in corporations. For example, changes in the US federal sentencing guidelines would give corporations extra credit if the "specific individual" in the corporation with "day-to-day operational responsibility for the compliance and ethics programme" has direct access to the board of directors.
Regulators are calling for a more independent compliance function within companies, but Ben Heineman says GCs and chief compliance officers must work in tandem
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