Uber launched a brand-new ad campaign in which it vows to “move forward” and “always do the right thing,” but the company still does not have a chief compliance officer (CCO) to make sure it delivers on that message. 

In a one-minute promotional video e-mailed to Uber customers Monday, CEO Dara Khosrowshahi touted the company’s “new leadership and a new culture,” ostensibly a nod to the organization’s series of missteps over the past year-plus that has shaken consumer and investor confidence.

The company, however, has been without a CCO since September 2017 and does not have anyone with compliance experience on its board of directors. The company is also reportedly without a chief financial officer as well. These roles are critical, because Khosrowshahi will have to certify the company is in compliance with relevant securities laws when it goes public. This includes not only accurate financial controls under Sarbanes-Oxley (SOX) but also effective compliance internal controls under the Foreign Corrupt Practices Act.

At this point, Uber is still aiming toward a 2019 initial public offering. But it first needs to create the infrastructure required of a company valued at $68 billion while trying to engage in a dramatic corporate cultural change. And all of this must be done in the public eye. Priority No. 1 should be hiring a CCO and putting an experienced, seasoned compliance professional on the board of directors.

Uber did manage to avoid one reputational headache after reportedly turning down a consulting offer from Trump lawyer Michael Cohen. It had the corporate sense that AT&T and Novartis failed to muster, but it still has a lot of work ahead. And that work should start with finding a CCO.

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