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CCO reporting to the board

Tom Fox | March 3, 2018

Chief compliance officer reporting to the appropriate board of director’s compliance committee has to be structured carefully to promote ethics and compliance.

Here are The Man From FCPA’s five best practices that should guide the reporting:

Quarterly Reports — The CCO should report in person to the compliance committee every quarter. If the CCO submits a written report and does not appear before the compliance committee, the failure to appear before the committee reflects a defective relationship. The quarterly report is critical for both the CCO and the committee to hear about compliance performance and challenges.

Executive Session – Every quarterly report should be concluded with an executive session where the CCO and the compliance committee can have a frank discussion on any potential issues. It is a valuable opportunity to raise important issues. An executive session demonstrates that the CCO is independent and empowered...

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