‚Compliance 1.0‘ Ain’t Dead Yet


Michael Peregrine wrote this bylined article criticizing assertions that a compliance model in which the compliance officer reports to the general counsel (called Compliance 1.0) is antithetical to good corporate governance. “We need to recognize that corporations have, by law, the freedom to make a decision on compliance and legal functions that they in good faith determine to be best suited for their particular circumstances. This isn’t a “them vs. us” situation … and it serves no useful purpose to approach the discussion that way,” Mr. Peregrine wrote.