The USDOJ has required an independent compliance function in some recent corporate settlements, but is this the official position of the Department? We discuss the the intersection of these recent developments, the US Federal Sentencing Guidelines and how this might relate to whether your compliance officer has the necessary independence to craft and maintain a compliance program that is effective. Just what are the expectations from the Department and can we ensure that that our compliance function will meet those standards? In this episode, Eric answers these questions and discusses just what independence a compliance officer must have to maintain an effective program. Eric also asks 3 questions of Bill Brown, Chief Compliance Officer of the Knights of Columbus. Bill Brown comes to the compliance and ethics field after many years service as a prosecutor. His background provides a unique perspective into the compliance and ethic space and great insight into the future.