Integrity Research Group and Altman Weil reported results from their study of compliance functions (Legal Week, Vol. 7, Oct. 13, 2005 at 84). Two-thirds of the survey’s participants have created a compliance function separate from the legal function.
Of those two-thirds, one-third of the compliance functions report to the CEO, one-third to the general counsel, and one-third to someone else. (See also my posts of July 31 about law and compliance under the same roof; Aug. 27, 2005 about Microsoft’s compliance function reporting to the General Counsel; Sept. 10, 2005 about Chief Governance Officers and compliance; M.L.E. Post of Sept. 17, 2005 noting that Citigroup’s huge compliance function reports to the chief risk officer; and Oct. 21, 2005 on where compliance should report.)