One topic that continues to pervade compliance conferences is organizational design. Where should the compliance function sit—within legal or compliance? Recently, Bank of America Corp. transferred its compliance group from the legal department to the risk control area. According to Reuters, the transfer is a result of federal regulators warning big banks to adopt more ethical internal cultures or risk being broken up. In our practice, we have the benefit of working with companies and colleagues that have many different structures. The truth is, as with many compliance program design issues, there is no one-size-fits-all solution.
But we realize that the answer “it depends” usually is about as satisfying as the end of a Green Bay Packers game. So we’ve come up with four considerations that organizations can use to evaluate the appropriate design for their compliance program: resources, history, culture and risk.
1. Resources
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