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Checklist for CCO direct reports

Tom Fox | May 14, 2018

In its Evaluation of Corporate Compliance Programs, released in 2017, the Justice Department raised several issues around chief compliance officer independence and authority. While the agency’s stated position is that it does not concern itself with whether the CCO reports to the general counsel or reports independently, it is concerned about whether the CCO has the voice to go to the chief executive officer or board of directors directly, without going through the GC first. Even if the answer were yes, the Justice Department would want to know if the CCO has ever exercised that right.

When making this evaluation, companies should consider the following questions:

  • First and foremost, is the CCO a part of the senior management or the C-suite? Is the CCO part of regular meetings of this group?
  • Who can terminate the CCO—the CEO, the audit committee of the board, or does CCO termination require approval of the entire board?
  • Most importantly, could a...
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