Volkswagen Emissions Scandal — Another Compliance 1.0 Train Wreck

Volkswagen Emissions Scandal — Another Compliance 1.0 Train Wreck

Donna Boehme – Corporate Counsel – October 6, 2015

As careful observers of the compliance field may have noted, the profession has spent more than a decade working to define itself. This has meant dispelling a number of persistent and dangerous myths that gave rise to a legacy Compliance 1.0 model (Compliance as a captive arm of Legal), which itself can be found at the roots of many of the big compliance train wrecks that litter the corporate landscape. It’s not too hard to understand the flawed reasoning that created Compliance 1.0 in the early days of the evolving profession:

  • “If it involves legal risks, it must be a subset of Legal”; which then led to
  • “Any general counsel or senior lawyer is qualified to be the chief compliance officer (CCO) and manage Compliance”; and then
  • “Why wouldn’t we appoint a big-name ex-prosecutor, ex-regulator or ex-law firm partner as CCO to impress our regulators, stakeholders and the financial press? This is too easy!”

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