Five Essentials of a Chief Compliance Officer Position


Most of Shakespeare’s histories involve issues relating to kingship and how a king might reign. In some of the plays, such as Henry V, the example is of a positive nature. In others, such as Richard III, you may need to draw from the inverse to see how one should decidedly not govern. The tragedies tend to emphasize a tragic flaw which brings down someone who is not necessarily a king, such as Hamlet or Coriolanus.

What are some of the characteristics of the position of a Chief Compliance Officer (CCO) for a company subject to the Foreign Corrupt Practices Act (FCPA), UK Bribery Act or other international anti-bribery and anti-corruption laws? That question was recently explored in an article in the Society of Corporate Compliance and Ethics (SCCE) bi-monthly magazine, Compliance & Ethics Professional, in an article entitled “Five essential features of the Chief Ethics and Compliance Officer position”, by author Donna Boehme. She believes that while all CCO positions should be “fit-for-purpose” there are five essential features which are consistent to all such positions.

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