Donna Boehme – Compliance & Ethics Professional – June 2015
2015 and 2016 will be very good years for the Compliance and Ethics profession. As I said here, Compliance 1.0 — Compliance as a captive arm of Legal — is on its way out, and the way has been cleared for the rise of Compliance 2.0, informed by the failures of its predecessor.
Let’s recap. In the early days, the unfortunate mantra was: “If it involves legal risks, it must be part of Legal.” Thus, Compliance became the captive arm of Legal. This meant that the role of chief compliance officer went to the general counsel himself, or to whichever member of the Law department happened to call in sick that day. #IHateWhenThatHappens. But, as Roy Snell, CEO of the Society of Corporate Compliance and Ethics, has noted, a compliance officer who is not independent and empowered is not a true compliance officer. And the headlines bear out these sad tidings. Both Wal-Mart and GM owe their headlines to a poorly structured Compliance 1.0 function that was designed to fail.
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