The Justice Department's Evaluation of Corporate Compliance Programs, updated September 2024, still asks whether the programme is designed for this line of business, resourced and empowered, and working in practice. Those questions attach to an officer, not to a panel partner who will leave when the exam ends. If the examination is in six weeks and you have no CCO, you need an interim this month and a retained search on the 10-week CCO clock (of 41 files). You do not need a partner to "hold the pen" and call it a programme.
ACC 2026 has privacy oversight at 40 percent of chief legal officers. That is a function the GC often still carries. It becomes a hire when the calendar is GDPR reviews, AI-Act obligations and customer DPIAs as a weekly load, not a project. Until then it is a hybrid: GC owns, intercept counsel surges, panel opinions on the novel questions.