Hiring an outstanding chief compliance officer (CCO) is necessary but not sufficient for effective FCPA compliance. To be effective, the right CCO needs the right tools – actual authority credibly conveyed by an appropriate title; access to the board and management; a workable reporting structure; sufficient budget; quality people; up-to-date technology; and a receptive culture. Few companies would dispute the notion that a CCO needs the foregoing tools, among others, to do his or her job well. But fewer still have a coherent and consistent approach to translating these concepts into practice. How, for example, can a company structure reporting lines to maximize the effectiveness of its CCO and minimize the likelihood of FCPA violations? What level of board access is appropriate for the CCO, and how can a company facilitate such access? This article addresses these and similar questions. In doing so, this article aims to help companies empower their CCOs and thereby minimize the probability and magnitude of FCPA and other compliance violations. Many of the recommendations in this article do not involve increased spending, but rather a more prudent allocation of resources, better informed structuring and refocused culture. More effective FCPA compliance is not just about spending more money; it’s about thinking differently, confronting reality and giving the right people the right tools.
Editor-in-Chief Rebecca Hughes Parker recently spoke with chief compliance officer and assistant general counsel at General Motors, Michael Ortwein, who shared his insights on top-of-mind issues in advance of his participation in this fall’s ACI FCPA Conference.
The full video is here. The associated article is here.
Editor-in-Chief Rebecca Hughes Parker recently spoke with IBM's vice president and assistant general counsel of investigations Una Dean, who will be co-chairing ACI's FCPA conference this fall, about a range of hot compliance topics.