As a passionate supporter of the compliance function, I continue to advocate for compliance officers and the importance of compliance to overall governance. Good compliance means good business – we all know that. Compliance always depends on interpersonal skills. A CCO is only as good as his/her ability to persuade and enlist commitments from senior management and related functions. Often I hear about problems CCOs...
Most compliance programs include some form of internal compliance committee separate from the company’s audit committee. An internal compliance committee can play a very important role in advancing a compliance program. But there are a number of pitfalls in how such committees are organized and how they operate. Let’s start with one critical preliminary question: Does your company’s compliance program have the full support of...
A chief compliance officer can get overwhelmed with responsibilities and initiatives. CCOs have a never-ending to-do list – once an initiative is finished, the CCO has to jump to another “priority.” CCOs are responsible for operationalizing the company’s compliance program. The CCO’s success depends on the cooperation of related functions – procurement, legal, human resources, security, finance, internal audit, and information technology. While there has...
Compliance practitioners are opportunists. They have to look for openings in the corporate resource world to build partnerships with related functions. To put it another way, they are purveyors of compliance thinking – they inject the compliance mindset into functions that can advance the effectiveness of compliance controls. When it comes to the vendor onboarding process, compliance practitioners need to participate in the design and...
