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This paper addresses the paradox that five years after the implementation of the Financial Services Act and despite the apparent mandatory nature of the compliance officer's function, no clear detailed definition or description of the role has emerged. By tracing the origins of the office through the legislation and regulation, the paper suggests that the general perception of the function derives only from the common responsibilities. The difficulty of further refining this perception is demonstrated by reference to several company or employer‐specific constitutional and cultural constraints. The paper concludes that, despite the importance of establishing a detailed understanding of the compliance function, assessment of the compliance officer's role will continue to be based on those elements of the function which are common to all and exclude those aspects which are unique to particular companies or groups.

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