Here we are at the beginning of the year – time for prognosticators and the making of resolutions. Everyone looks ahead, whether you do so in the form of resolution or goal. For most organizations – big, small, public, private, local, global, etc. – one of their main objectives is most likely to implement or expand a solid corporate compliance infrastructure that can insulate them from various internal and external threats. Someone within that organization is responsible for carrying the GRC flag, and that person is usually the chief compliance officer.
Of course, he or she may go by other names depending on the size and shape of the enterprise. The point is, your chief compliance officer is an incredibly valuable asset, positioned as they are at various critical intersections within your business. Such was the case in 2011, and the same will be true for 2012. Michael Volkov, a former federal prosecutor, wrote in his Corruption, Crime & Compliance blog that the CCO should be named “person of the year,” because, Volkov says, the CCO “has taken on more responsibilities and been asked to do more with less” and calls them “the unsung corporate heroes who are immediately blamed when a problem occurs but rarely praised as companies improve compliance performance.”
In light of an increasingly heavy burden of regulations and laws, it’s the CCO who stands resolutely on the front lines, waving that battle flag. There is the ongoing fracas over Dodd-Frank, the Volcker Rule and other financial reform and reporting matters; the renewed bite of the FCPA and False Claims Act; the UK Bribery Act and Basel III reforms; plus not to mention all of the various regulations for specific industries and business types. The chief compliance officer is often caught in a crossfire between the board of directors, the CEO, the CFO, the general counsel, auditors, regulators, etc., as he or she wages war against corruption and misconduct.
We’re on your side, and we really do feel your pain. Don’t take it from me; take it from Michael Mann, a former director of the office of international affairs at the SEC and associate director of the agency’s enforcement division. In a recent Compliance Week interview, Mann says this: “Whether it deals with whistleblower, bribery, insider trading, fraud, or other subjects, the focus of [the SEC and Department of Justice] is on the operations of your compliance program…. Regulators are going to worry about businesses cutting back on the non-performing or revenue-generating side of business, compliance being one of them. They are sending out the message that is the area you want to invest in.”
CCOs, stand strong. More and more of your fellow leaders are seeing the light of compliance.