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Do the Sentencing Guidelines require an independent chief compliance officer? & Three Questions with Jennifer Badgley

The US Sentencing Guidelines require that individuals within an organization be delegated with day-to-day operational responsibility for the compliance program. When defining the role of this individual, the Guidelines say that the person with day-to-day operational authority shall report to high level personnel, and when appropriate, the governing authority of the organization on the effectiveness of the program. In addition, the Guidelines require that the individual responsible for the compliance program have adequate resources, appropriate authority, and direct access to the governing authority. Does this mean that the chief compliance officer or the employee tasked with day-to-day operation of the compliance program have complete independence? Should this person report solely to the Board of Directors or a sub-group of the Board of Directors? What does “adequate resources” and “appropriate authority” mean? Eric answers these questions and discusses how to ensure that your program meets the requirements of these Guidelines. 

Eric also asks Jennifer Badgley, Director of Compliance & Ethics at Premera Blue Cross, Three Questions. Listen to her talk about her journey to compliance after working in internal audit at Bank of America and learn why she finds compliance to be a personally rewarding field. 

If you a question you want answered on the podcast be sure to submit it on or reach out below.

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