There are three prisms by which the structure of the Chief Compliance Officer position can be evaluated: access, resources, and opportunities. They were originally articulated in the 2012 FCPA Guidance. Since that time, the Justice Department has consistently talked about the structure of the CCO position. In speeches by Justice Department representatives in 2014 and 2015, the structure of the position was discussed. Under the Justice Department FCPA Pilot Program, the CCO structure was specifically called out for evaluation as a part of a best practices compliance program. These comments were carried forward under in the Evaluation of Corporate Compliance Programs, released in February 2017.
