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As a general rule, many chief compliance officers (CCOs) were lawyers at one point in time in their career. This made sense given the multitude of laws that continue to be involved with maintaining compliance. In addition, great CCOs tend to have a keen understanding of business operations, trusted relationships with the leaders of the business and an integral relationship with the CEO, CFO, CIO and GC.
Today, while these characteristics are still needed, the proliferation of corporate integrity agreements (CIAs), deferred prosecution agreements (DPAs) and other agreements require a CCO and his/her team to have an operations and program management mindset. As a result, there is a small but growing population of compliance executives that are not lawyers but know business operations very well and can execute enterprise-wide initiatives effectively, while leveraging the legal function throughout.
One way that companies can have a strong mix of legal, compliance and operational talent is by rotating business executives into and out of the compliance function or, conversely, compliance executives into and out of business functions. This would be a long-term strategy that would yield significant benefits as long as it is integrated into an effective leadership and talent management process.
Global compliance issues continue to challenge the industry as it grapples with growing the business in countries with differing business practices. Although tax inversion issues have been front and center lately, life sciences companies continue to manage issues like global trade compliance, fraud and corruption. Historically, these issues were handled more so by hiring compliance executives from local markets. More so today, ex-pats are being hired into foreign compliance roles in conjunction with local personnel. There is a delicate balance to having the nonlocal compliance efforts be driven through local personnel who are viewed as part of the culture. Identifying, recruiting and retaining the right global talent for compliance roles continues to be a fundamental challenge for our industry.