• Richard Bistrong

Due Diligence Questions Chief Compliance Officers Should Ask In A Job Interview

Updated: Sep 11

The following guest post is by Maurice Gilbert, Managing Partner of Conselium Executive Search.

Earlier this month I posed a question to Chief Compliance Officers around the world: “Since today’s regulatory climate means you may face increased personal liability for corporate wrong-doing, what due diligence questions are you now asking potential employers and Boards before accepting a CCO position?”

The results were enlightening.  Are today’s CCO candidates concerned? Yes. Are they doing more due diligence before joining a company?  Definitely. Were they eager to share examples of questions they’ve been asking in interviews?  You bet.

As a compliance-focused executive recruiter, I know the Yates Memo isn’t simply changing the way Chief Compliance Officers do their jobs — it’s changing the way they look for jobs.  So what follows is a growing list of due diligence questions.

As this list has made the rounds on social media over the past few weeks, it’s expanded– and it will continue to, with your help.  Drop me a line if you have questions of your own to add.

Feel free to print and save this list.  You can download a pdf here.

Here we go:

  1. What keeps you up at night?

  2. What’s the major compliance issue currently facing the company?

  3. Do you believe employees are comfortable in reporting potential ethical/compliance infractions?

  4. Is there a whistle-blower policy? How does it work and what does it cover?

  5. Why is the position open?

  6. If someone was previously in the position, what were the circumstances of his/her departure?

  7. Prior to hiring me, would you permit me to meet privately with the chair of the board or committee responsible for compliance oversight?

  8. What keeps you up at night?

  9. For any prior government sanctioned infraction, what are the lessons learned? What changes have been made?

  10. What do you believe to be the greatest regulatory compliance risks facing the company?

  11. What do you believe to be the greatest business risks facing the company?

  12. What do you believe to be the greatest geographic risks facing the company?

  13. Describe the relationship between the company and the regulators

  14. What are the main challenges for a CCO in the coming nine months?

  15. Are there any areas where the compliance program is not meeting management or board expectations?

  16. Do you believe employees are comfortable in reporting potential ethical/compliance infractions?

  17. Have you ever had an outside evaluation of your compliance program?

  18. Is there anything you believe management can do to support the compliance program?

  19. What is the budget/staffing for the Compliance function?

  20. What are the reporting lines for the role?

  21. Can the CCO veto a Due Diligence target?

  22. At what stage is the compliance department involved in establishing a relationship with a business partner?

  23. At what stage is the compliance department involved in the M&A process?

  24. Is it customary for the CCO to sit in operations meetings pertaining to new products and market initiatives so as to advise the business on risk?

  25. What role do you see Compliance playing in management meetings?

  26. What is the formal frequency of reporting to the Board and what is the policy for Board reporting on an as needed basis?

  27. Have executives in your organization ever walked away from a business opportunity for ethical and/or compliance concerns?

  28. Do you feel ethics/compliance is an essential part of a successful business or something that’s just a reality you have to deal with these days?

  29. Do you think that ethical business practices do in fact lead to a more successful business if done the right way?

  30. How do you view the compliance officer – as part of the business or an external function?

  31. What did or didn’t you like about working with their former CCO?

  32. What sort of questions have you raised to the previous Compliance Officer? Have questions been purely technical or have they extended to broader business practices?

  33. What do you and Board leadership think about regulatory compliance risk and whether it is viewed proactive or only reactively?

  34. How do you think compliance can be a strategic partner in achieving your goals? Is it more just “keep us out of trouble?”

  35. Are there ways you believe the compliance program could be a strategic advantage for the company in terms of its health and growth?

  36. How would you describe the values of the leadership team and what does the tone at the top look like?

  37. Who has authority to fire me?

  38. What are you offering in the way of liability protection?

  39. Am I free to engage my own counsel if necessary in a response to a government investigation?

  40. Can I go to outside counsel on issues before discussing with General Counsel?

Have you road-tested any due diligence questions in a compliance job interview?  The threat of personal liability will drive the importance of the due diligence process, so this list of questions can – and will – grow and change in the coming months and years.  Share your input below and be part of the process.

Click here for a downloadable/printable version of the questions.

Maurice Gilbert is Managing Partner of Conselium Executive Search, which specializes in placing Compliance Officers and Legal Counsel for clients in the U.S., Europe, Latin America and Asia Pacific. Maurice is also CEO of Corporate Compliance Insights, a worldwide publication devoted to governance, risk and compliance issues. Maurice can be reached at maurice@conselium.com 


Interesting article? Would you like to know more?Contact Me

#MauriceGilbert #RichardBistrong

  • White LinkedIn Icon
  • White Twitter Icon
  • YouTube
  • White Facebook Icon
  • White Instagram Icon

Interested in connecting with Richard?

©2020 by Front-Line Anti-Bribery LLC

Keep the conversation going with Richard!