Chief compliance officers may want to re-read that old copy of The Prince and go for the office power grab in 2010. Apparently all the cool kids in corporate governance support you already.
Within the last several months, we’ve seen numerous signs—regulatory settlements, best practices guides, proposed revisions to the U.S. Sentencing Guidelines—that federal regulators and the governance-industrial complex now believe a corporation’s top compliance overseer should report straight to the CEO, if not straight to the board. First was the Justice Department’s settlement with Pfizer Corp. last fall over improper drug marketing. The most interesting part of the deal (other than the $2.3 billion fine) was a lengthy corporate integrity agreement specifying that the chief compliance officer report directly to the CEO and meet with the audit committee of the board at least quarterly. The wording was clear:
