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Compliance Concepts

You're the New Chief Compliance Officer; Now What?

July 16, 2018

by Howard Haykin


In his Corruption, Crime & Compliance blog column, attorney Michael Volkov offered prospective new Chief Compliance Officers advice on:

  • questions you should resolve before accepting the position; and,
  • five basic steps to get started once you've been hired.


Now, we'll offer the 5 basic steps, and let Mr. Volkov to 'put some meat on the bones'.


  1.  Meet with your compliance team
  2.  Meet with your “operational” partners, meaning your natural partners and supporters in the compliance space – HR, legal, internal audit, controller, CFO, security (if the company has an office), and IT. 
  3.  Meet with business leaders and key managers. 
  4.  Develop a tentative game plan
  5.  Bring your vision to senior leadership and the audit committee. 


At the conclusion of this process, a CCO will know whether he or she will be facing an internal political struggle that will complicate his or her assignment or whether the challenges can be overcome with the support of senior leadership.