Tagged: Chief Compliance Officer

Episode 58 — Interview of Donna Boehme — The Future of the Independent, Empowered Chief Compliance Officer

Donna Boehme is our guest on this week’s podcast.  She is an advocate for an independent, and empowered Chief Compliance Officer. Donna is an internationally recognized authority in the field of organizational compliance and ethics with over 20 years’ experience designing and managing compliance and ethics solutions, within the US and globally. As Principal of Compliance Strategists LLC, she has advised a wide spectrum of private,...

Welcome! You Are the New Chief Compliance Officer: Five Basic Steps to Get Started

Congratulations on your new position as the chief compliance officer.  You successfully interviewed with the company, met the senior executive team and the audit committee chair, and negotiated a nice compensation package.  You are feeling “pretty, pretty good” (ala Larry David) about your new job and looking forward to starting your new position. So, now, what do you do? My first question for you is...

The New Test for CCOs

These are inspiring times for the compliance profession.  Looking back on the last ten years, it is amazing to observe the growth and influence of the compliance profession.  Many of the original advocates for the compliance profession must be impressed.  Corporate leaders are now embracing a new mantra – ethics and compliance. Business ethics is a new focus and language all to itself. At the...

CCOs and CFOs: Bringing Everyone Together

Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies — most especially their business partners – to commit and devote time and resources to ethics and compliance. In order to operationalize their programs, CCOs have to build relationships with important partners – human resources, legal, internal audit, procurement, and finance. Up to this...

CCO’s and Delusions About a Company’s Ethical Culture

It is easy to say something and convince yourself it is true. As George Costanza advised Jerry Seinfeld when Jerry had to take a polygraph examination when he failed to admit that he watched  “Melrose Place,” “Remember Jerry.  It’s  not a lie, if you believe it.” See Video Here. This statement from this Seinfeld episode (Season 6, Episode 16) reminds me of compliance professionals who...

Is Your Chief Compliance Officer Lonely?

Compliance officers have a tough job. In most cases, they are overworked, under-resourced, and accountable for significant risks and issues. In the recent compliance vernacular, a CCO has to “operationalize” the company’s compliance program. That requires a CCO to go out and make friends inside the company. CCOs have “natural” friends – legal, internal audit, human resources, and security – which share many common objectives...

DOJ’s Compliance Program Evaluation: the Role of the CCO (Part II of IV)

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...

Making Sure Business Ethics Has a Seat at the Table

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...

When Lawyers Cross the Line – Breaking Bad Under the Law

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...