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The compliance oversight committee

Tom Fox | November 26, 2017

The Compliance Oversight Committee sits between the CCO and the board’s compliance committee, and its role is to provide oversight and review of items such as third-party approvals and renewals, requests for payments from third parties, and significant gift, travel, and entertainment requests from employees. There should be some type of oversight which can be reviewed on a monthly or quarterly basis as part of a company’s management of risk.

As far back as January 2005, the Deferred Prosecution Agreement (DPA) entered between the Department of Justice and the Monsanto Company provided for “the establishment and maintenance of a committee to supervise the review of (I) the retention of any agent, consultant, or other representative for purposes of business development or lobbying in a foreign jurisdiction,” or an oversight committee. It should be clear the role of the compliance oversight committee is not to substitute its judgment for that of the CCO, but rather to provide... To get the full story, subscribe now.