The role of the chief compliance officer continues to be a hot, confused, and contested topic, as reflected in Catherine Dunn’s March 29 CorpCounsel.com article, “General Counsel, Chief Compliance Officer . . . or Both?”
What does the CCO do: ensure good process or enforce strict compliance? To whom does she report: GC/CFO, CEO, or the board? What is her role in shaping the corporation’s voluntary adoption of ethical standards beyond what the law requires?
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