Starting a Compliance Program From Scratch (Boehme quoted)

Starting a Compliance Program From Scratch

Karen Kroll – Compliance Week – March 13, 2012


As many compliance officers know, being a compliance department of one, even with some administrative support, is difficult enough. What if you’re an organization’s first-ever compliance officer? How do you go about building a program from scratch?

The initial and most important step is ensuring that the program is correctly positioned, says Donna Boehme, principal with Compliance Strategists. “The correct selection, positioning and structuring of the compliance officer and compliance function within the company—getting this step right can make the difference between good self-governance and becoming the next Wall Street Journal headline.”

That means that the chief compliance officer needs enough autonomy from management that he or she can speak independently, yet be confident of being heard, Boehme says. Increasingly, strong compliance programs have their compliance officers report to the organization’s chief executive officer, rather than the general counsel. The officers also enjoy direct access to the board of directors.

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