A chief compliance officer’s job can be challenging, to say the least. When things are going smoothly the CCO may be seen as an inconvenience, a cost center to be consulted only occasionally and perfunctorily to minimize drain on the company’s budget and management’s time. But when a compliance failure occurs, the CCO must immediately be on top of the situation, brimming with business-minded insights and advice delivered with conviction and creditability borne of unquestioned independence and expertise. What could be easier, right?
One key to a CCO’s success is his or her ability to establish that essential credibility from the outset and then maintain it through thick and thin. An indicator of that success is the extent of the CCO’s access to the company’s board of directors. Unfortunately, sustained substantive access to the board can be tricky to pull off. After all, the CCO generally has little influence over the board’s agenda and may feel that it is inappropriate to interact directly with board members outside of a formal board meeting.
