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Harry Cassin
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Andy Spalding
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Jessica Tillipman
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Richard L. Cassin
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
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Chief compliance officers are saying so long to the general counsel

A new survey of chief compliance officers found that 38 percent of those with overall program responsibility report directly to their company’s CEO, while just 18 percent report to the general counsel or chief legal officer.

Nineteen percent of the chief compliance officers report directly to the board of directors, the survey by the SCCE and NYSE Governance Services found.

Of those who don’t report directly to the board, 79 percent said they have dotted line reporting to the board.

The rest of the respondents report to a vice president of finance, financial controller, or other vice president.

The survey was taken across industries and among big and small companies from June to August this year.

More than half (56 percent) of the surveyed organizations give the person with overall responsibility for the compliance and ethics program the title of chief compliance and/or ethics officer or compliance and/or ethics officer.

Seventy-two percent of the responding organizations have an internal committee dedicated to compliance and ethics. And 71 percent of the internal compliance and ethics committees have “cross-functional representation” and a documented charter.

Nearly all (93 percent) of the internal compliance and ethics committees hold regularly scheduled meetings at least quarterly. Among the topics typically discussed during committee meetings are upcoming initiatives (81 percent), training initiatives and statistics (81 percent), legal and regulatory updates (76 percent), and policy management and updates (75 percent).

Most organizations (79 percent) have a charter or detailed written description for the compliance and ethics function. And 71 percent of the organizations have formally documented the delegation of the oversight of the compliance and ethics function to a person or committee.


The full SCCE and NYSE Governance Services 2014 Compliance and Ethics Program Environment Survey is here (pdf).


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.

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