Compliance Departments Face Hard Questions During the Downturn

Writing on the FCPA Blog, Richard Cassin speculates on Covid19’s impact on compliance departments. When cash reserves vanish companies run daily headcounts to survive, and no one is exempt including compliance personnel. The question as he sees it is whether the department will shrink or disappear. Given the fact that public companies have by now identified compliance risks in repeated disclosures, and detailed responses that involve a program run by compliance officers, it’s unlikely that any CEO or board of directors would allow themselves to be exposed to the potential liabilities they’d face if they closed their compliance department completely. That doesn’t mean chief compliance officers are home free. They’ll have to make the case for each aspect of the department’s work and the people who implement it. Can they be cut? That’s the question CEOs and boards will be asking every day. Cassin would like to hear from readers about how their departments are faring.