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Feature Boehme of Contentionby Donna BoehmeMachiavelli and the 2011Person of the YearCompliance & Ethics Professional March/April 2012“There is nothing more difficult to take in hand, more perilous toconduct, or more uncertain in its success, than to take the leadin the introduction of a new order of things.”(Niccolo Machiavelli, 1532)BoehmeEverything old is new again. Machiavellimay have been the first to observe theperilous nature of the chief complianceofficer job (in my book, it’s right up there withcoal miner and deep sea fisherman), but nearlyfive centuries later, former federal prosecutorMichael Volkov has echoed thoseearly observations by naming theCCO the 2011 “Person of the Year.” 1CCOs are the “unsung heroes,” saysVolkov, noting “there are institutionalforces which hold them backfrom achieving their mission.” Towhich we can almost hear beaten butyet unbowed CCO’s everywhere responding“THANK YOU!”In many respects, 2011 has been a “perfectstorm” for compliance. Commentators havecited unprecedented levels of enforcementand new regulation, the controversial Dodd-Frank whistleblower regime, the Volckerrule and financial reform, UK Bribery Act,record-breaking FCPA and qui tam settlements,the rise of social power, and the entryof Generation Y into the workforce. 2011also marked the twentieth anniversary ofthe Federal Sentencing Guidelines, promptingthe Ethics Resource Center to assemblea committee to offer recommendations topolicymakers. Support for the role of theempowered CCO should be at the very top ofthe ERC agenda, because the unspoken truthwe must shout from the rooftops is that, alltoo often, CCOs are positioned for failure. 2According to a new SCCE/HCCA survey, 58%of compliance professionals surveyed felt isolatedand in an adversarial position, and 60%considered leaving their jobs in the last yeardue to stress. 3 What the Person of the Yearreally needs to be successful is empowerment,direct unfiltered reporting to the board,adequate autonomy from management, andsufficient resources. Earth to Boards: Try thatfor “tone from the top.”Volkov also predicts that the CCO willbe elevated to C-suite status within the nextfive years. This would be fast work, givenMachiavelli’s “institutional forces” underminingthe CCO mission. Will 2012 yield bettercompliance? Only to the extent boards, government,and policymakers create levers ofempowerment to position the Person of theYear for success instead of failure. ✵1. Michael Volkov: “The Person of the Year – The Chief ComplianceOfficer.” Corruption, Crime & Compliance online, December 15,2011. Available at http://corruptioncrimecompliance.com/2011/12/theperson-of-the-year-the-chief-compliance-officer.html2. See RAND Symposium Report “Perspectives of Chief Complianceand Ethics Officers on the Prevention and Detection of CorporateMisdeeds.” Available at http://www.rand.org/pubs/conf_proceedings/CF258.html3. HCCA and SCCE: “Stress, Compliance, and Ethics” survey, January2012. Available at http://www.corporatecompliance.org/staticcontent/StressSurvey_report.pdfSend comments to Donna Boehme at dboehme@compliancestrategists.com.26 www.corporatecompliance.org +1 952 933 4977 or 888 277 4977
COMPLIANCE PROGRAM ADVISOR Last Year’s Best Practices Are This Year’s Standards“Think about how you might tailor the Guidance to your organization. And know that, as you do, the Criminal Divisioncares about all the things you might be considering – “tone from the top” support, encouragement of a culture ofcompliance that rewards ethical behavior and establishes whistle-blowing mechanisms, senior-level oversight anddirect reporting lines, [and] periodic reviews and re-evaluations to test and ensure program effectiveness …— Assistant U.S. Attorney General Lanny Breuer,Prepared Remarks to Compliance Week 2010: 5th Annual Conference“Contact Ethisphere today to obtain additional information regarding Compliance Program Advisor subscription package optionsat info@ethisphere.com, 1.877.629.8724 and/or www.ethisphere.com/compliance-program-advisor/
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