Kusserow on Compliance: Advice for compliance officers taking on a new engagement

One of the great hurdles for someone moving into a new position is meeting the expectations of the organization.  Kash Chopra, JD has served as compliance officer on multiple occasions.  Among her duties at Strategic Management is providing clients with interim compliance officers to fill gaps between permanent appointments. She found that in far too many cases, new compliance officers inherit a host of problems, many of which can be of longstanding nature. and in a very short time the interim compliance officer will come to own these problems. She advises that at the time an organization notifies a person that they been accepted for the position as compliance officer, that person should request an independent compliance program evaluation in order to find out the status of the program and just exactly what they are inheriting. If possible, it is helpful to include having an independent evaluation performed to be part of negotiating terms of the engagement. Not taking this step may result in having the job get off to the wrong start and lead to piecemeal reporting of problems as they are encountered. This seldom plays well with management or the board. The better play is to let the outside reviewer identify the problems, and have the new compliance officer focus on the solutions. It will make clear to the executive leadership and the board that the flaws, weaknesses, and exposures identified belongs to the predecessor. Such a review should also provide a road map of what needs to be done to ensure the program is on the right track. By taking this approach, the new compliance officer will be seen as cleaning up the problems.

Kash Chopra can be contacted for more information on interim compliance staffing or independent compliance program evaluations at kchopra@strategicm.com or (703) 535-1413.


Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2018 Strategic Management Services, LLC. Published with permission.