Counterpoint: CCO, GC independence is critical

Matt Stankiewicz – Compliance Week – September 27, 2019

The battle over the separation of the general counsel and chief compliance officer roles has been raging for well over a decade now.

It’s been 16 years since the Tenet Healthcare compliance fiasco, when Senator Chuck Grassley noted, “It doesn’t take a pig farmer from Iowa to smell the stench of conflict in that arrangement” when discussing the dual-hatted role of Christi Sulzbach, the company’s general counsel and chief compliance officer. It became clear at that time that legal and compliance needed to be independent to properly function.

Fast forward to the present and we see the compliance profession has undergone significant evolution. What was once a fledgling profession has blossomed into an area recognized by most major federal agencies as being not just important, but necessary to the core team of every major corporation. The Department of Justice’s Criminal Division just rewrote its initial guidance. The DOJ’s Antitrust Division provided its evaluation criteria in July. Even the Department of Treasury joined the party by providing its “Framework for OFAC Compliance Commitments.”

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