Day 24 of 31 Days to a More Effective Compliance Program-CCO Authority and Independence

The role of the Chief Compliance Officer (CCO) has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the 10 Hallmarks of an Effective Compliance Program, the focus was articulated by the title of the Hallmark, Oversight, Autonomy, and Resources. This Hallmark was significantly expanded in both the Evaluation of Corporate Compliance Program (Evaluation) and the new FCPA Corporate Enforcement Policy (Policy).