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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Where does your compliance chief sit?

Image courtesy of FacebookThe New York Times asked who’s sitting near the big bosses at Google and Facebook. It turned out the best seats are now occupied by teams working on artificial intelligence.

“I can high-five Mark and Sheryl from my desk, and the AI team was right next to us,” Facebook’s chief technology officer, Mike Schroepfer, told the Times.

The Google Brain team — mathematicians, coders and hardware engineers — recently moved from another building to a spot near Sundar Pichai, Google’s CEO. The Brain team is focused on accelerating AI research through a new breed of computer chip, the Times said.

“It is a very significant statement that [Pichai] has moved that group right next him,” Google executive and Alphabet director Diane Greene said.

Proximity to decision-makers means access. It also sends a message to the rest of the organization and beyond about what’s important, and what’s not.

Then there’s the impact on the workers themselves. You’d expect those sitting near Mark and Sheryl to be jazzed, high fiving anyone within range.

It’s hard to imagine a lot of high fives happening around the cubicles in corporate Siberia.

In elementary school there were always kids who pushed to the front row. Maybe they thought being near the teacher would earn them better grades. (Come to think of it, most of them did get better grades than the rest of us.)

Even at church, some of the flock can’t resist front-row pews. “Closer to the Vicar, closer to God,” the Anglicans say.

And finally . . . . we come to our point.

Where does your chief compliance officer sit? Is it inside the C-Suite? Or is it two floors below the second vice president for sales?

What we’re asking is, Can seating charts predict a company’s future?

We don’t know. But Google and Facebook apparently think so.

Maybe they’re right. So maybe sending a compliance chief to the cheap seats is predictive of a coming FCPA disaster.

Until organizational forensics prove otherwise, we wouldn’t bet against it.


Richard L. Cassin is the publisher and editor of the FCPA Blog.

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  1. And we thought a seat at the table was a tough gig to muster? A perm seat in the C-suite is perhaps moving that relationship up a notch and for good reason. and speaking of Facebook, it will be interesting to see to the degree Cambridge Analytica's access to information about 50 million Facebook users highlights the importance of the Compliance function; and not just having the policies; but also making sure compliance controls and risk assessments are continuous, and properly operationalized.

  2. You are absolutely right to raise this question, and it highlights an important point. For a compliance program to be effective, the chief ethics and compliance officer (CECO) needs “authority,” i.e., power. One element of this is proximity to power. If the CECO is not at the same spot as the big bosses, then that is one of the clearest signs that the program is not empowered.

    I sometimes read commentary by academics bemoaning how hard it is to assess whether a compliance program is real or fake. I disagree. Here is one of the easiest ways to do this. If the CECO lacks power, the program is not real. If the CECO is located away from the real power, that is a clear sign the program is not empowered and not likely to be effective.

    Compliance programs are about management. It is tough to manage something if you are kept away from it. The closer the CECO is to the real power in the company, the more likely it is that the company is serious about compliance.

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