A CCO’s most valuable resource is time. But with high expectations and limited resources to do the job well, CCOs can quickly become overwhelmed. Michael Volkov provides a framework for dealing with some of the role’s greatest challenges.
Chief compliance officers have a hard job. CCOs know that fact, and they fully embrace the challenges of their positions. At the same time, CCOs have extraordinary expectations placed on their shoulders – they are rarely complimented about their programs while the company avoids major controversies, but they are among the first to be questioned when a compliance breakdown occurs.
CCOs are always busy. Everyone understands why; they have high expectations, often limited resources, outdated technologies and competing, political demands on their activities.
I often witness this phenomenon: CCOs explain they rarely focus on their “to-do list” and spend most of their time “putting out fires” or responding to a senior executive’s demand. CCOs regularly complain that they get to the end of the day and have had no time to focus on their priorities.
This can be a trap. A CCO’s performance is not measured by how busy they are – being busy does not necessarily translate into quality of performance. To put it bluntly, running from fire to fire does not necessarily mean that a CCO is doing a good job.
CCOs have to apply a cost-benefit analysis to their own activities. Warren Buffet and Bill Gates recently conceded that the most valuable commodity they have is their time. CCOs have to do the same analysis.
For CCOs, the danger of being overwhelmed is significant. CCOs have a huge portfolio for which they are responsible, and they often lack basic resources to carry out their job. Their difficulties are compounded by the fact that CCOs are dependent on the cooperation and performance of related functions in the company (e.g., human resources, finance, information technology), over which the CCO has no authority.
CCOs have to examine their specific responsibilities and tasks, turn a critical eye to each and ask some basic questions.
Responsibility: Is this a task I should be responsible for? If not, who should be responsible for completing the task?
Accountability: Can I hold that person accountable?
Information: Do I need to know any information about the performance of that task?
Communication: Have I delegated this task to the appropriate person and communicated my expectations as to performance?
This basic framework provides a way for a CCO to prioritize his or her responsibilities and then make sure any delegation of responsibility is properly executed.
CCOs need to rationalize their activities, delegate where they can do so or address specific needs in other ways (e.g., seeking assistance from another function or securing additional resources (human or technology)).
An overwhelmed CCO is a risk unto itself, and CCOs need to guard against such a threat. It is easy to get lost in a job, and it takes discipline to preserve a person’s ability to perform their job effectively.
This article was republished with permission from Michael Volkov’s blog, Corruption, Crime & Compliance.
Michael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services. He can be reached at 
