What is an important first step in creating or improving a compliance team?

An important first step in creating or improving a compliance team is placing the Chief Compliance Officer (CCO) on the senior management team. This step is crucial because it ensures that the compliance function is integrated into the strategic decision-making process of the organization. When the CCO is part of the senior management team, it promotes a culture of compliance across all levels of the organization and allows for direct communication with other executives regarding compliance issues.

Additionally, having the CCO at the senior management table enhances the visibility and importance of compliance within the organization. It allows for the identification of risks and the implementation of effective compliance strategies to be prioritized alongside other critical business objectives. This integration can lead to more robust compliance programs by ensuring that compliance considerations are included in organizational planning and operations.

While the other choices hold significance—ensuring senior management dedicates time to compliance improvements and giving the CCO authority to modify policies are also important aspects—they are not as foundational as the positioning of the CCO within senior management. Without the CCO’s presence in a key leadership role, initiatives related to compliance may lack the necessary support and alignment with the overall goals of the organization.