Power Struggle Between the Third Man and Leading Compliance Chiefs
In the world of corporate governance, the role of the Chief Compliance Officer (CCO) has become increasingly significant. This role, which is central to a company's compliance and ethics program, is analogous to the enigmatic character, Harry Lime, in the classic film, "The Third Man".
According to Donna Boehme, a renowned expert in the field, a successful CCO must be independent within an organization. Much like Lime, who operates in the shadows but is essential to the story's unfolding, a CCO must have autonomy from management to effectively carry out their duties.
The 2011 Amendments to the U.S. Sentencing Guidelines reiterate this need, emphasizing the importance of specific individuals being delegated day-to-day operational responsibility for the compliance and ethics program. This responsibility, Boehme notes, should be given to individuals who have adequate resources, appropriate authority, and direct access to the governing authority or an appropriate subgroup of the governing authority.
Interestingly, the corporate official(s) assigned this responsibility also have direct reporting obligations to independent monitoring bodies, including internal audit, the company's Board of Directors or any appropriate committee of the Board of Directors. This ensures a checks-and-balances system, much like the intricate web of relationships in "The Third Man".
The film, based on a book of the same name by Graham Greene, stars Joseph Cotten as protagonist Holly Martin and Orson Welles as Harry Lime. The story revolves around Martin searching for Lime in post-war Vienna, meeting his girlfriend and various shady characters. In a dramatic turn of events, Martin leads the Military Police to Lime, resulting in a final noir-classic chase through the sewers of Vienna.
The ongoing debate in the compliance world about the role of the CCO and the General Counsel (GC) mirrors the complex relationships portrayed in "The Third Man". Boehme cites Michael Volkov, another notable figure in the field, stating that a successful CCO must be independent within an organization, much like Holly Martin in his pursuit of justice.
While the film has been restored in a new digital version and is opening in select theaters this week, the role of the CCO continues to evolve in the corporate world. According to a PwC Compliance Survey, only 29% of CCOs have made it into the C-Suite, but this is expected to increase. The Department of Justice's minimum best practices requirement for a Foreign Corrupt Practices Act based compliance program includes the assignment of responsibility to one or more senior corporate executives for the implementation and oversight of the company's anti-corruption policies.
Before making any decision or taking any action that may affect a business, it's crucial to consult a qualified legal advisor. The author of this article does not render business advice, legal advice, or other professional advice or services, and this publication should not be used as a basis for any decision or action that may affect a business.
The author permits linking, posting, distributing, or referencing this article for any lawful purpose, provided attribution is made to the author. The movie ranks in the top 10 greatest movies of all time according to the author, making it a must-watch for those interested in the intricate world of corporate governance and the parallels it shares with classic cinema.
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