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CCO authority and independence

Tom Fox | January 3, 2018

The role of the chief compliance officer has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the 10 Hallmarks of an Effective Compliance Program, the focus was articulated by the title of the Hallmark, Oversight, Autonomy, and Resources. In it, the 2012 FCPA Guidance focused on whether the CCO held senior management status and had a direct reporting line to the board. It also advises companies to “consider whether the company devoted adequate staffing and resources to the compliance program given the size, structure, and risk profile of the business.”

This Hallmark was significantly expanded in both the Evaluation of Corporate Compliance Program and the new FCPA Corporate Enforcement Policy. The Department of Justice’s Evaluation of Corporate Compliance Programs made the following query about the CCO position.

There is a new requirement for compliance “independence.”...

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