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KPMG 2019 CCO Survey Identifies Ethics and Compliance Areas for Enhancement

KPMG 2019 CCO Ethics & Compliance Survey


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Investigations, Monitoring & Testing and Training Top List
Across Most Industries, Heightened Awareness of Behavior
Has Elevated Ethics and Compliance

A new report by KPMG LLP shows a consensus across industries that enterprises plan to strengthen their ability to detect and prevent ethical misconduct by enhancing key compliance areas of investigations, monitoring and testing, due diligence and governance. This comes in light of recent technology advances and expanding digitization that have accelerated an increasing convergence of business models and markets across disparate industries – and which have focused awareness on high-profile events such as data breaches, questionable sales practices and organizational misconduct.

The report, “KPMG’s 2019 CCO Survey: Insights for the future of ethics & compliance,” points out that most organizations, independent of industry, are taking ethics and compliance risks seriously. Based on a survey of 220 chief ethics and chief compliance officers (CCOs) representing the largest organizations in various industries, the report identifies mature ethics and compliance areas and offers guidance for improvement where necessary. To download the full report, go to:

“There is a growing consensus across all industries regarding the key areas organizations need to focus on and enhance, not only in ethics and investigations but also on the maturity of ethics and compliance programs,” said Amy Matsuo, KPMG principal and Regulatory Insights national leader. “This is likely driven not only by a commonality of risks but also converging business models.”

The report identifies the top five areas where CCOs plan enhancements to their enterprise-wide ethics and compliance activities: investigations (65 percent), monitoring and testing (65%), data analytics (32%), regulatory change management (32%) and reporting and data visualization (32%).

The report found that Board of Director engagement in ethics and compliance oversight and supervision is strong, and that business line accountability for ethics and compliance is well-established. However, it also said the ethics function continues to need to work on achieving a “trusted advisor” relationship with the business front lines.

KPMG’s report provides insights and suggestions that organizations can implement for more integrated and effective investigations programs in the areas of people and skills, process and data analytics, and technology, including:

  • Revamping investigations processes, case management, reporting and communication
  • Embedding accountability via ethics- and compliance-driven employee metrics
  • Continuing to drive integrated governance and reporting across Ethics & Compliance, Legal and Human Resources departments
  • Evaluating available data and the integrity of that data for use in predictive analytics enterprise-wide
  • Establishing guardrails and new risk processes for evolving business digitization, data analytics, and automatio
  • Investing in technology and/or tools to drive greater data access, quality and automation to compliance monitoring, testing and enhanced data analytics
  • Continuing enhancements to scans and the inventory of regulatory changes and dynamically link to associated operational controls
  • Elevating and/or redesigning ethics and compliance to integrate with business operations

“Increased public awareness and regulatory focus – along with market pressures for greater agility and real-time responsiveness to identify misconduct – are driving organizations to improve their investigations function,” Matsuo said. “Integrating investigation activities more closely with ethics and compliance risk management by enhancing investigation reporting and investing in new technology, such as AI, can help to consistently identify and analyze root causes and trends and improve the production of investigation resolutions.”  

About the Survey

The KPMG CCO survey was completed in January 2019. The survey asked chief ethics and chief compliance officers for their views on key areas of ethics and compliance focus and integration, as well as key program maturation areas relative to KPMG’s proprietary Compliance Program framework. Participants operate in the following industries: consumer markets; energy and natural resources; financial services, including banking, capital markets and insurance; healthcare and life sciences; industrial manufacturing; and technology, media and telecommunications.


KPMG LLP is the independent U.S. member firm of KPMG International Cooperative (KPMG International). KPMG International’s independent member firms have 207,000 professionals working in 153 countries and territories. Learn more at


Christopher G. Bacey
Twitter: @KPMGUS_News

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