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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

The Big Story of 2018: Compliance Officers

It was a breakout year for compliance officers and compliance professionals, making them the big story of 2018. As I said mid-year, they’re rock stars now, famous and wanted.

Some stories about them from the FCPA Blog during 2018:

Alstom appointed a compliance officer, Sylvie Kandé de Beaupuy of Airbus, to its board of directors. Lisa Osofsky, a career-long compliance pro, became head the UK SFO. To recover from the horrible Larry Nassar sex abuse scandal, Michigan State University appointed law prof Nicholas Wittner as the university’s first chief compliance officer.

FIFA hired an American compliance officer to help clean up the corruption mess that has tainted world soccer. Ukraine nearly appointed Baker McKenzie’s Tom Firestone as the auditor for the National Anti-Corruption Bureau. China’s ZTE reached a plea deal with the U.S. Commerce Department that called for an embedded American compliance team (née monitors), appointed by Commerce.

A compliance training video produced by Mastercard that tells Richard Bistrong’s FCPA story won several top media awards in 2018.

There’s a global shift toward compliance culture.

Enforcement agencies and regulators in the United States and elsewhere now expect and often require companies to have deep and demonstrable compliance cultures. The creators and caretakers of that culture, naturally enough, are compliance officers.

Strengthening the compliance culture has become a standard remediation for companies dealing with corruption problems. (At least 17 companies from about a dozen countries have talked about culture in recent FCPA-related disclosures, according to FCPA Tracker. Airbus, Telia, SNC-Lavalin, Rio Tinto, Barclays, ING, and Eletrobras are among them.)

A November 2018 SEC filing from Goldman Sachs about its role in the 1MDB scandal preemptively blamed Goldman’s own poor compliance culture in Southeast Asia.

More emphasis on compliance raises the compliance officer’s profile.

Compliance is breaking out everywhere. The International Olympic Committee is now obligating host cities and their Olympic organizations to adopt anti-corruption and human rights compliance. The Paris 2024 Olympics committee is relying on a French compliance group, Le Cercle de la Compliance, to create a framework and monitoring system for the coming Games.

More big economies are requiring compliance programs, hence compliance officers. See, for example, Russia, Brazil, Argentina, and Mexico, among others. DPA negotiations typically emphasize the importance of compliance officers, both before the problem happened and after. Now joining the United States and the UK in using deferred prosecution agreements to resolve corporate bribery cases are Japan, France, Canada, Australia, Argentina, Singapore, and Israel.


There it is. The year 2018 brought more attention than ever to compliance officers and compliance pros, along with greater expectations on them.

Coming up: The big story for 2019.


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

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1 Comment

  1. This is an interesting article, Richard. I like the positive outlook.

    I do wonder, however, if 2018 may have been the peak for compliance officers. My thought is that the big story of compliance officers was anti-corruption driven and that anti-corruption initiatives are forecast to decline. I base this prediction on the current political climate (protectionism, "regulatory pendulum swinging back", slowing growth rates, recessions). Sure enough, politicians claimed that anti-corruption laws (and other regulation) put market participants from economies with stricter regulation at a disadvantage and called for less regulation and less compliance.

    In view of the above, it is not unreasonable to predict that 2018 will be looked back upon as the last big year for compliance officers and compliance professionals — the final tour of these rock stars if you will.

    I hope I am wrong. Anyway, watch this space.

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