Compliance officers and business managers need each other, whether they like it or not. The CCO has to enlist the business to own and take responsibility for compliance. Compliance cannot ensure compliance throughout an organization. If the business takes ownership of compliance, the organization has a chance to achieve an effective ethics and compliance program. If the business avoids such responsibility, the company might as...
We all know that a compliance program without business buy-in is, by definition, an ineffective compliance program. The level of business support ranges from “mouthing” support to full-fledged embrace and ownership of compliance program controls. By “mouthing” support, I am referring to business staff who say they understand compliance, use the right words reflecting an understanding of compliance issues, but they fail to attend to,...
Everyone likes to cite and talk about the list of horrible scandals. Whether it is Enron, WorldCom, Siemens, GM, VW, Wells Fargo, we pick through the details, cite failures and use it as a springboard to a discussion of higher ideals and performance. Call it a reminder of worst-case scenarios. The rise in the chief compliance officer is based on the need for corporations to...
