31 Days to a More Effective Compliance Program - Day 25 | CCO authority and independence

Thomas Fox
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The role of the CCO has steadily grown in stature and prestige over the years. In the 2020 FCPA Resource Guide, under the Hallmarks of an Effective Compliance Program, it focused on the whether the CCO held senior management status and had a direct reporting line to the Board.

The FCPA Corporate Enforcement Policy and 2020 Update make the importance of a best practices compliance program even more critical. The DOJ is focusing more on the See more +

The role of the CCO has steadily grown in stature and prestige over the years. In the 2020 FCPA Resource Guide, under the Hallmarks of an Effective Compliance Program, it focused on the whether the CCO held senior management status and had a direct reporting line to the Board.

The FCPA Corporate Enforcement Policy and 2020 Update make the importance of a best practices compliance program even more critical. The DOJ is focusing more on the role, expertise and how the compliance function is treated within an organization. Pay your CCO considerably less than your GC? You may now better be able to justify that discrepancy. If you have a legal department budget of $3 million and a compliance department budget of $500,000; you may be starting behind the eight-ball.

Three key takeaways:

1. How can you show the CCO really has a seat at the senior executive table?

2. What are the professional qualifications of your CCO?

3. Does your CCO have true independence to report directly to the Board of Directors? See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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