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A compliance officer’s wish list

In the holiday spirit, here’s a last glance back at 2013 and a look at how the compliance profession is doing.

When I started legal practice over 30 years ago, there were no anti-corruption compliance departments and no  “ethical business culture” issues. Today the law mandates both.  

On the other hand, drawing from 2013 posts, here is a top ten list of open items:

10. Students cannot do an undergraduate major in compliance nor an MBA or PhD. Compared to lawyers or accountants and to business executives, compliance officers cannot get an equivalent license or credential. 

9. Influential consulting firms and business schools don’t highlight compliance issues as they do other business issues.

8. Chief compliance officers do not routinely report to Boards and Boards do not require members to have compliance expertise or to undergo training.

7. Compliance programs have gaps that miss C-Suite misconduct; unethical “lawful but awful” decision-making is not corrected by CEOs or Boards.

6. The DOJ/SEC Guidance and enforcement actions do not specifically recognize abuse of compliance officers.

5. Transparency International, the OECD, UNODC, and the World Bank publish compliance standards and handbooks for business that do not mention the role of compliance officers.

4. Journalists ignore the plight of compliance officers who prevent scandals or warn management but suffer retaliation as a consequence.

3. Boards and CEOs have not taken a public pledge to stop retaliation against compliance officers and whistleblowers.

2. American compliance officers overlook the different and dangerous working conditions of COs outside the USA.

1. To the global public, COs are invisible, even though they are the unsung heroes inside companies fighting corruption and misconduct.

There is work to be done for the profession to gain respect, resources, and allies. 

We must: Explain what we do and why the world needs it; ask for what we want; and argue for why we deserve it. That is called advocacy.

Here’s to a peaceful, happy holiday season and best wishes for advocacy in the New Year.


Michael Scher is a contributing editor of the FCPA Blog. He has over three decades of experience as a senior compliance officer and attorney for international transactions. He is affiliated with ethiXbase, the owner of the FCPA Blog. He can be contacted here.

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  1. Another issue: Financial Services firms often insist that the CO gets registered (I.e. Series 7 and Series 24, etc) when those registrations actually don't come close to what the CO actually does for the firm. Al that registration does is allow the regulators to look at the CO as a supervisor (which he shouldn't be) when an issue comes up.

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