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Donna Boehme: CCOs are voting with their feet, and that’s good

I know that the compliance professionals in my networks understand, now more than ever, that choices have consequences.

Last May at Compliance Week 2016, I began to hear the impact of CCOs voting with their feet.

And a number of surveys confirm that compliance professionals are voting for positions that are structured to succeed, opting to apply their compliance SME to design and manage compliance programs at companies that are serious about compliance and culture, and not just seeking “window-dressing” to impress regulators, the media, and other stakeholders.

Compliance SME earned through years in the trenches and the profession is a valuable commodity, and CCOs are voting with their feet for roles and companies where they are likely to be supported in building robust, effective programs, rather than being fired, in Mauritza Munich fashion, for doing their jobs well. Those votes are being counted and carefully noted, by recruiters, employers and other gatekeepers. Well done EthiTweeps, way to support the profession!!

The FCPA Pilot Program is only one example of regulators paying closer attention to how compliance functions and programs are structured, including the “quality and experience,” “independence,” “compensation and promotion,” and “reporting structure” of compliance SMEs,” indicating that the way is being cleared for the rise of the new model of compliance.  

As noted by former federal prosecutor Mike Volkov: “At the heart of the DOJ’s statement is a commitment to nurturing of the compliance function. For compliance professionals, they must have read the listing as music to their ears.” Well, it is music to my ears that CCOs are voting with their feet and using every opportunity to educate recruiters on the flaws of the failed Compliance 1.0 model.

And so onwards with the building of strong, successful Compliance 2.0 programs that actually work to find, fix and prevent problems!  

Compliance professionals should be focusing their efforts on these areas:

  • Ensuring their C-Suites and Boards are educated in modern Compliance issues and models.
  • Using all available resources and networks to build strong, effective programs that “work” to find, fix and prevent misconduct before your company is forced to do so on the terms of third parties, as VW,  GM, and now Wells Fargo so vividly demonstrate.

Remember that you are the Compliance SME in your company, and thus responsible for developing that SME in your teams, functional partners, management, board, and others in your circle. This will help produce a stronger program, and at the same time, support the profession on many levels. Because #RisingCCOLiftsAllBoats!


Donna Boehme is the Principal of Compliance Strategists LLC. She has advised a wide spectrum of private, public, governmental, academic and non-profit entities on organizational compliance and ethics. @DonnaCBoehme

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  1. Great posting Donna (as usual). Compliance 2.0 is the inevitable result of the rise of the compliance profession. Your tireless advocacy is a primary reason for this movement. Keep up the great work!

  2. Many thanks Mike. The next phase is for all CCOs and compliance professionals to use their C 2.0 roles to produce and manage robust programs. We are on the right track now!

  3. What does SME stand for?

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