31 Days to a More Effective Compliance Program: Day 26 – CCO Authority and Independence

Thomas Fox - Compliance Evangelist
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Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us See more +
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

On Day 26, we ponder the evolving stature and authority of the CCO within organizations, as highlighted by recent guidelines and regulations. The 2020 FCPA Resource Guide emphasizes the importance of the CCO’s direct reporting line to the board and senior management status. The DOJ’s updated Corporate Enforcement Policy has further enhanced the prestige and role of the CCO, introducing key factors like the quality, experience, authority, independence, compensation, and reporting structure of the CCO. The episode also touches on the significance of the Delaware Court of Chancery’s decision in the McDonald’s case, which formalized the oversight duties of corporate officers, positioning the CCO as the second-most important role in an organization. Key takeaways include demonstrating real authority for the CCO, evaluating their professional qualifications, and assessing their actual status within your company.

Key highlights:

1. Key Inquiries Around the CCO and Compliance Function

2. Importance of CCO Certification and Court Decisions

3. Critical Takeaways for Compliance Professionals See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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