General Counsel (GC) And Chief Compliance Officer (CCO)

Introduction

Compliance is an enterprise-wide responsibility that does not pertain to any one department. The General Counsel (“GC”) and Chief Compliance Officer (“CCO”) both exercise compliance functions in an organization. Different regulations such as the Sarbanes-Oxley Act of 2002 and the United States Federal Sentencing Guideline (“Guidelines”) have specified what they expect from an organization regarding the adoption and execution of an effective compliance program. Generally, the duties of the compliance department in an organization (public or private) is intertwined to that of the legal department, and both have a duty to perform during an internal audit of the organization. To adequately discuss the view that the GC and CCO should

Compliance Officers act within a management role as the liaison between the board of directors and the organization because if there is a reported case of misconduct, the compliance officer conducts internal investigations, and report findings to the

While the CCO oversees the promotion of healthy corporate practices by educating employees, the GC oversees the legal compliance functions under the oversight of the Board. The CCO’s managerial duties entail creating an atmosphere for effective communication in the organization, training and educating employees (new employees as well), creating policies and procedures guidelines and ensuring a standard code of conduct. These are not the duties of the GC. It is a combined effort, each having to issue independent reports on the process and outcome; it may be too cumbersome for one person to perform both functions where they