Empowering Compliance Officers: The Key to an Effective Compliance Program

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4 Responses

  1. Michael,

    a terrific blog, which stresses the right points. This should be a must-read for every CEO. The only point where I disagree is your thought on Risk Managers and Risk Officers. The compliance risks are only one area of risks for an enterprise. There should not be different risk management procedures for economical risks and compliance risks, this should end up all in one company risk report. Of course, the CCEO has to provide his input of compliance risks in the overall risk assessment process, but responsible for the overall process and results is the risk officer and not the CCEO.

    Thomas

  2. Donna Boehme says:

    Michael,
    Another great, insightful column on the independent, empowered CCO. In a recent RAND Symposium on Leadership and Culture (May 16, report pending), a recurring strong theme was the role of the independent CCO as the single most critical factor (after active, meaningful senior management commitment) for an effective compliance program vs. your “bare bones” or paper program. I addressed this same issue in my invited 2009 RAND white paper http://compliancestrategists.net/sitebuildercontent/sitebuilderfiles/Rand1.pdf. I would add to your description of positioning 2 items 1) seat at the table where important decisions are made (not just emergency access to the board) and 2) no “carve outs”. Many companies set up a CCO with a badge and a gun and then “carve out” critical risk areas such as FCPA, Antitrust or Safety from CCO oversight and the compliance program. The CCO does not have to be the subject matter expert or doer, but she does have to hold oversight & line of sight.

    On the issue of CCO as Risk Officer, in my view that’s a little tricky because compliance and ethics risks are just a subset of overall company risks, and many will be outside the natural subject matter expertise of the CCO. It can be done under certain circumstances (but not others!) but requires caution. I wrote an Op Ed on this topic earlier this year http://compliancestrategists.net/sitebuildercontent/sitebuilderfiles/agenda.11.21.2011.ceco.risk.pdf

    Again, thank you for this terrific column and your strong support of the empowered CCO role.When someone of your background and expertise speaks out on this topic, it is very powerful. (I will feature it in tomorrow’s newsflash.)
    Donna Boehme

  1. May 21, 2012

    […] officials. Tom Fox explains how to do compliance through the lens of the Homestead Act. Mike Volkov empowers compliance officers and runs through some nightmare scenarios. Thebriberyact.com has a guest take a […]

  2. May 21, 2012

    […] officials. Tom Fox explains how to do compliance through the lens of the Homestead Act. Mike Volkov empowers compliance officers and runs through some nightmare scenarios. Thebriberyact.com has a guest take a […]