Episode 39: The Next Great Transformation of the CCO

In this podcast, Marie Patterson and Jay Cohen discuss the changing role of Chief Compliance Officers (CCOs). New developments in compliance underscore the evolving role of CCOs, with wider responsibilities and increased influence within organizations. Topics discussed in this episode include:

1. Evolution of Compliance Officer Role: They discuss the historical background of compliance officers and how guidelines from 1991 emphasized effective compliance programs. The Caremark case in 1996 established the duty of directors to oversee compliance risks, including information systems and red flags.
2. Recent Changes: They delve into a recent Caremark case that extends compliance responsibilities to corporate officers, not just directors. This means the CEO and CCO now share company-wide compliance duties.
3. DOJ's Influence: The US Department of Justice's guidance is shaping compliance expectations, emphasizing a culture of compliance, empowering officers to raise concerns, and prioritizing ethics over profit.