Released earlier this month with little fanfare, the Department of Justice Criminal Division Fraud Section released guidance on how to evaluate the effectiveness of a corporate compliance program. The document has Compliance Counsel Hui Chen’s fingerprints all over it, as the DOJ has again expressly endorsed the key attributes of the modern Compliance 2.0 model: empowerment, independence, a seat at the table, line-of-sight, resources, and, of course, true Compliance SME — the important foundational element of a successful compliance function.
Emily Glazer – The Wall Street Journal – February 2, 2017
The Wall Street Journal discusses the shuffling at the chief compliance officer position within J.P. Morgan. Of note, the “Journal reported last year that regulators are focusing more on who compliance executives report to give them more independence from executives who set policies and manage people in the field.”
My comments on this are:
- Simply focusing on reporting lines is not enough. That’s why we added seat at the table, empowerment, line of sight, and resources to the analysis.
- It’s nice to see this becoming part of the lexicon.
- Four CCOs in four years is the Compliance 1.0 red flag I have written about-> A CCO “revolving door” should show regulators and gatekeepers that something is very wrong in a company’s compliance approach or culture.