Have you ever seen the media coverage of a corporate scandal say, “Penalties for the [safety/environmental/bribery] violations were waived because they occurred outside the chief compliance officer’s line of sight and accountability”? Me neither.
It’s a fairly simple concept. The CCO is expected to have, and should have, the compliance oversight for all high-risk areas of the company. When evaluating the effectiveness and strength of a compliance function, “line of sight” is one of the first things prosecutors and regulators should look for. It is one of the key criteria that make all the difference between a compliance program that looks good on paper and one that doesn’t work at all in practice.
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