Fcpa Compliance Report

Welcome to Day 3 of 30 Days to a Better Compliance Program. Today I want to consider the Chief Compliance Officer (CCO) in your organization, through three prisms: access, resources and opportunities.  Access What access does your CCO have to the top decision makers in your organization? While it really does not matter whether the CCO reports to the CEO, Board or GC; it does matter that the CCO have direct access to corporate decision maker. Resources This means both head count of personnel to operate your compliance function and the money available to implement the appropriate technology to sustain an effective compliance program. If your compliance team is run on a shoestring, you will likely be downgraded for your overall commitment to doing business in compliance with the FCPA. Put another way, if you spend more on paper clips than on your compliance program, your compliance program may well be under-funded.  CCO Pay, Opportunity and Expertise  In the Pilot Program, the DOJ laid out another important ele