Compliance Officer _and_amp; CFO 2841
can a CFO chief financial officer get the function of compliance officer without violating the Segreagation of duties requirements ?
thanks in advance
KerryOne last edited by
My simple answer would be ‘no’. Not for SOX/financial statement controls. BUT, as with all other SOD issues there can be mitigating controls. I’d need more inormation about the size and type of your company. WE are a smaller public company and use an outside ‘hotline’ (phone and online access) that sends any report made to our ‘compliance officer’ (chair of audit committee) and to the CFO… as long as the CFO is not mentioned in the report.
I would agree that the CFO should not be addressing any complaints raised that accuse him of misconduct, but I don’t think that this precludes him from being the chief compliance officer, especially in a smaller company with limited resources.
thanks for replies
we are small entity less than 50 employees responding to a multinational oversized
of course, we have small possibility to get enough independent persons to ensure enough SOD
but the question is despite the fact that people are innocent until the against fact occured; if the compliance duties is given to the CFO, is there any additionel controls or procedure that would have to be implemented to conver this SOD?
and what is the problem to give compliance officer position to independent person fron financial dept, if we ensure to provide her with the required empowernement ?
thanks in advance
Make sure that you understand what duties are given to the CFO as compliance officer. The term might mean different things to different people. Once you understand the responsibilities, then you can determine if any SOD issues exist and address how best to mitigate them.
In other words, don’t get caught up with the title of compliance officer thinking that the title precludes him from performing certain tasks.
the question would be what would be the activities nature in CFO position which would arise SOD matters while he’s doing his CO activities?
because if he is nominated CO, he’s taking the whole duties of this position.
Tell me what you think a chief compliance office does and where you feel that there will be a conflict of interest.
Well roughly f
i would say in case tracking , accouting , LOA , anti trust matters, relating to line management backgroung
kind of stuff?