Sometimes compliance issues are simple. Most times they are nuanced. This is a simple issue but it carries with it a significant message. So here goes – where is the CCO’s office? To clarify rather than complicate, let’s take ourselves out of the remote workplace. In the physical office, where is the CCO’s office located? I am a big fan of the movie Office Space...
Each year, Michael Volkov reviews current trends concerning the state of the chief Compliance Officer. As we witness the continuing growth in stature of the CCO, it is important to exercise caution and realistically evaluate future trends and concerns.
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns. We have to recognize that 2020 was a difficult and unusual year for CCOs, given the panoply of risks, the disruption to every organization, and devastating impact of the COVID-19 pandemic. CCOs were forced into a new environment where health and safety issues,...
To start the New Year, it is a good idea to review the trends in the role and status of Chief Compliance Officers. As we witness the continuing growth in stature of the CCO, we need to exercise caution. Some troubling concerns are becoming apparent. With a new Attorney General and Biden Administration, CCOs have to be mindful of their ever increasing responsibilities and concomitant...
We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the tangible benefits of an ethical culture, companies are striving to achieve such a goal. Unfortunately, there is no single solution to companies that want to establish...
DOJ’s Compliance Evaluation highlights important trends in the role and independence of the Chief Compliance Officer. DOJ has stopped short of requiring direct reporting of a CCO to a CEO or other senior officer but it is inching closer to such a demand. In the topic area relating to Stature [of a CCO], DOJ lists important issues for a company to consider in designing its...
While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer crossing the line – from lawful to unlawful. Not only did the Embraer legal executive know about the bribery scheme, the executive was the one who came up...
