New Guidance on Compliance Officer “Independence”

Michael Peregrine wrote this bylined article on a new Justice Department position that corporate compliance and legal functions need not be separate. “This is a critical distinction, as many health system boards are grappling with complex enterprise risk management challenges that require coordination amongst executives with risk oversight responsibilities,” Mr. Peregrine wrote. He added that the real concern is “how can compliance officers and general counsel work collaboratively to build and maintain a comprehensive organizational and coordinated organization risk and compliance program, in which the board may have confidence.”