How to Structure Chief Compliance Officer Reporting Lines to Maximize the Efficacy of Anti-Corruption Compliance (Part Three of Three)

To whom a company’s chief compliance office reports fundamentally affects the authority of the CCO, directly influencing the effectiveness of the company’s anti-corruption compliance program and the company’s reputation and revenue.  However, there is little guidance, official or otherwise, on how to best tailor a reporting structure to a company’s needs.  To help companies with this critical task, the Anti-Corruption Report is publishing a three-part series on compliance reporting lines.  This, the third article in the series, explores the pros and cons of having the CCO report to both the board and a member of management, provides a roadmap for CCOs handling compliance violations (including insight from the former head of compliance at AIG), explores how CCOs can protect themselves from liability and discusses how companies should evaluate their reporting structures.  The first article in the series addressed the recent trend of companies shifting away from direct reporting of compliance to the legal department, discussed guidance provided by the government on this topic, outlined various issues a company should consider when choosing a reporting structure and explained why there is no one-size-fits-all solution to this compliance quandary.  The second article explored the benefits and drawbacks of five different reporting line structures.  See also “Five Tools Every Chief Compliance Officer Needs for Effective FCPA Compliance: Title, Authority, Access, Budget and Culture (Part One of Two)” (Apr. 3, 2013); Part Two of Two, Vol. 2, No. 8 (Apr. 17, 2013). 

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