Miriam Baer on Compliance Elites

Miriam Baer, professor of law at Brooklyn Law School, joins the Business Scholarship Podcast to discuss her forthcoming article Compliance Elites. In this article, Baer evaluates the tendency of firms to hire “elite” chief compliance officers (CCOs) who have had successful prior careers in private law firms and government enforcement agencies. Although this practice does potentially signal a firm’s commitment to its compliance function, Baer considers the risk that elite CCOs who have always been high performers may have “performance blind spots.” These blind spots, in turn, could reduce elite CCOs’ ability to assess whether performance results reflect, or performance goals encourage, fraud or other misconduct.