I get a kick out of the intellectual banter about the new/old administration’s willingness to put leadership in jail and the DOJ Yates memo that states the DOJ is going to go after leadership. Debate is raging about the veracity of the claims. All the while CEOs are being dragged out into the street and being pummeled by an angry mob of the press, public, and politicians such as former Wells Fargo CEO John Stumpf. It used to be that we would get our day in court and a full review of the facts. Not anymore. The press, public, and politicians have become the judge, jury, and executioners. Forget the enforcement community (figuratively speaking), fear the press, public, and politicians.
Slaying CEOs has become an extreme sport. Not all CEOs have instructed people to break the law. Not all CEOs have been informed of the wrong-doing. Not all CEOs are guilty and many actively support building an ethical and compliant culture. Those of you who always blame the CEO are going to be wrong on many occasions. And that is inappropriate. This article is for those CEOs who want to do the right thing and are depending on others in their company to help them do the right thing.
Get a real compliance officer. Hire someone who will tell you when it stinks. Get someone who has committed to the compliance profession, maybe even certified as a compliance professional by their profession. Get someone who has some evidence of studying the profession and networked with their peers. If you are considering someone who has never been a compliance officer before… you are betting your career on a rookie. And for goodness sakes don’t let anyone block your compliance officer or filter what they have to say. Make sure the right person is hired. Make sure they are tied to your hip. Why would you do otherwise when you see what is happening to your peers?
And if there is anything you take from this article… understand this, having a background in law, or risk, or ethics, or audit does not qualify someone as a Chief Compliance Officer of a large company. I would never bet my career on someone who has never held the job of Chief Compliance Officer no matter what degree or job experience they have had. The individual you seek has the training they need to overcome your other advisors who occasionally won’t speak up, rationalize doing nothing about a problem, or heaven forbid… try to keep people from, “turning over the rock” or looking for problems. You want an effective Chief Marketing/Financial/ Operations/etc. Officer, but the Officer that has the biggest impact on you personally… is the Chief Compliance Officer. Get involved and get it right. Your job, career, reputation, and your personal financial well-being depend on it.
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