Do Former Prosecutors Make Good CCOs?

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2 Responses

  1. Elliot Fisch says:

    Michael good comments although I don’t necessarily agree a federal prosecutor is the only way to handle compliance issues if the employees know that the CCO is a former federal prosecutor this only solidifies the policeman effect of the prosecutor and the Compliance program. My experience with companies with small staffs is to have a well trained Audit group control the Compliance review with oversight from the legal department so that when action is necessary legal will obtain the proper resources as necessary.

  2. Frank Numann says:

    I like your blog. Thank you for challenging the notion. You write: But do they know what an effective ethics and compliance program looks like? Good question. More importantly: do they know how to design and implement an effective ethics and compliance program? That’s an altogether different skill…