With federal agencies turning up the heat and investigative and enforcement activities on the rise, 81 percent of compliance officers are increasingly apprehensive about their personal liability in situations of corporate misconduct, according to a new survey released by DLA Piper.
The findings of the 2016 Compliance & Risk Report: CCOs Under Scrutiny revolve around the tone and articulation of priorities emanating from Washington: regulators and enforcement authorities are increasingly viewing the establishment of ethical and compliant business cultures as one of the most important tasks for corporate boards and C-suite executives.
Nearly every compliance officer should be looking at taking certain fundamental steps that address these issues. The list here should serve as a starting point. As always, execution and persistence are key.
- Mitigate CCO risk: CCOs should take steps to mitigate their liability in case of crisis or litigation.
- Report via channels: CCOs should set up the proper channels to access the CEO, GC and board of directors.
- Conduct thorough training: Train all employees, from top to bottom, using a plan that makes training timely, accessible and engaging.
- Assess risks regularly: CCOS should stay current on regulatory developments, organizational changes and policy updates to diagnose noncompliance and risks to business operations.
- Get cyberinsurance: CCOs should work with their cyber-security teams to review cyberinsurance for the company and its vendors.
- Report to the board: CCOs, for both public and private companies, should collect and analyze all relevant data and analyze to develop a qualitative pictures of the company’s compliance and regulatory trends and issues.
- Monitor, monitor, monitor: CCOs should employ a variety of resources to observe all business units and gather monitoring data.
With federal regulators ever more open about their willingness to prosecute individual corporate employees and incentivize reforms, the time to comply is now.
Find out more in our 2016 Compliance & Risk Report: CCOs Under Scrutiny.