The Trump Organization’s Compliance Program Begins

Last week, the Trump Organization kicked off its compliance program by making two appointments.

Bobby Burchfield will be independent ethics adviser. He’ll be responsible for signing off on transactions that could raise ethics or conflicts of interest concerns.

George Sorial will become chief compliance counsel.

In the January 11 press conference, Sheri Dillon announced:

[T]o ensure the Trump Organization continues to operate in accordance with the highest and legal ethics standards, an ethics adviser will be appointed to the management team. The written approval of the ethics adviser will be required for new deals, actions, and transactions that could potentially raise ethics or conflicts of interest concerns.

“Another step that President-elect Trump has taken is he created a new position at the Trump Organization: the position of chief compliance counsel, whose responsibility will be to ensure that the Trump businesses, again, are operating at the highest levels of integrity and not taking any actions that could be perceived as exploiting the office of the presidency.”

I admit that I was skeptical that the Trump Organization would even make the appointments to these two positions and I did not expect that it would happen this quickly. Of course, it would have been better to have a compliance program in place before the inauguration.

It would seem that the Trump Organization did not have an existing compliance program. The obvious person to deal with the compliance issues related to his political office would have been the compliance head.

Mr. Burchfield is a partner in the Washington office of King & Spalding and a well respected lawyer for the Republican party. He represented George W. Bush in the 2000 Florida recount. Mr. Burchfield previously challenged the McCain-Feingold Campaign Finance Law on behalf of the Republican National Committee. He was general counsel to George H.W. Bush’s 1992 reelection campaign. He is on the board of Crossroads GPS, the Republican advocacy group started by Karl Rove.

Mr. Sorial has worked at the company since 2007 and served most recently as executive vice president and counsel. He has had roles in Trump’s international development efforts, including the building of his golf course in Aberdeen, Scotland.

As I wrote last week, Mr. Trump is currently one of the most powerful men in the world and therefore the compliance program for his business empire is one of the most important in the world.

Mr Burchfield is very experienced lawyer who does tremendous work for his clients. I’m disappointed that the ethics advisor is such a partisan attorney for the Republican party.

As for Mr. Sorial, I will have to state my bias. Like him, I came from a real estate background. I also went to law school with him. However, he is stepping into an extremely difficult position with no background in compliance.

Hopefully, compliance professionals will learn more the compliance program so we can see how one is put in place to protect one of the most powerful people in the world. Obviously, the American people deserve to know more about the program to know whether the President is directly benefiting financially from his government actions.

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