Hiring a Chief Compliance Officer?

QUESTIONS CCO CANDIDATES ARE ASKING MANAGEMENT & THE BOARD

Are today’s CCO candidates concerned about personal liability? Yes. Are they doing more due diligence before accepting a job offer??

I recently posed a question to Chief Compliance Officers around the world: “Since today’s regulatory climate means you may face increased personal liability for corporate wrong-doing, what due diligence questions are you now asking potential employers and Boards before accepting a CCO position?”

The results were enlightening. Are today’s CCO candidates concerned? Yes. Are they doing more due diligence before joining a company? Definitely. Were they eager to share examples of questions they’ve been asking in interviews? You bet.

As a compliance-focused executive recruiter, I know the Yates Memo isn’t simply changing the way Chief Compliance Officers do their jobs—it’s changing the way they look for jobs.

What follows is a growing list of due diligence questions. If you’re a hiring authority, be ready to respond.

1. What keeps you up at night?
2. What’s the major compliance issue currently facing the company?
3. If someone was previously in the position, what were the circumstances of their departure?
4. For any prior government sanctioned infraction, what are the lessons learned? What changes have been made?
5. What do you believe to be the greatest regulatory compliance risks facing the company?
6. What are the main challenges for a CCO in the coming nine months?
7. Are there any areas where the compliance program is not meeting management or board expectations?
8. Do you believe employees are comfortable in reporting potential ethical/compliance infractions?
9. Have you ever had an outside evaluation of your compliance program?
10. Is there anything you believe management can do to support the compliance program?
11. What is the budget/staffing for the Compliance function?
12. What are the reporting lines for the role?
13. Is it customary for the CCO to sit in operations meetings pertaining to new products and market initiatives so as to advise the business on risk?
14. What role do you see Compliance playing in management meetings?
15. Have executives in your organization ever walked away from a business opportunity for ethical and/ or compliance concerns?
16. Do you feel ethics/compliance is an essential part of a successful business or something that’s just a reality you have to deal with these days?
17. What sort of questions have you raised to the previous Compliance Officer? Have questions been purely technical or have they extended to broader business practices?
18. What do you and Board leadership think about regulatory compliance risk and whether it is viewed proactive or only reactively?
19. How do you think compliance can be a strategic partner in achieving your goals? Is it more just “keep us out of trouble?”
20. Who has authority to fire me?

Maurice Gilbert is Founding Partner of Conselium Compliance Executive Search, which specializes in placing Compliance Officers and Legal Counsel for clients in the U.S., Europe, Latin America and Asia Pacific. Maurice is also CEO of Corporate Compliance Insights, a worldwide publication devoted to governance, risk and compliance issues. Maurice can be reached at [email protected]

Maurice's Linked-In page is: https://www.dhirubhai.net/in/mauricegilbert/