As many compliance officers know, being a compliance department of one, even with some administrative support, is difficult enough. What if you’re an organization’s first-ever compliance officer? How do you go about building a program from scratch?

The initial and most important step is ensuring that the program is correctly positioned, says Donna Boehme, principal with Compliance Strategists. โ€œThe correct selection, positioning and structuring of the compliance officer and compliance function within the companyโ€”getting this step right can make the difference between good self-governance and becoming the next Wall Street Journal headline.โ€