Moving Compliance Out of the General Counsel's Office: JPMorgan Chase and United States, ex rel v. Halifax Hospital Medical Center

One unavoidable cost of doing business for organizations operating in complex regulatory environments is the establishment and implementation of an effective ethics and compliance program. To ensure that the compliance program is not simply a paper program and, in practice, meets the criteria outlined by Congress and the U.S. Sentencing Commission for an effective compliance program, the organization must also decide whether or not, and to what extent, general counsel should control or supervise compliance and whether or not the organization might instead benefit from the formation of an autonomous compliance function headed by a chief compliance officer...