Outgoing CCO can also enjoy future payday as a whistleblower.

Christine Hohmann-Dennhardt, the outgoing chief compliance officer at Volkswagen, recently received an 8-figure payout, while the German automaker continues to deal with lingering issues associated with an emissions-cheating scandal that could lead to more than $25 billion in penalties.

So of course, questions are being raised about the payment. When Hohmann-Dennhardt’s departure was announced, Volkswagen said it was a mutual agreement to part over “differences in their understanding” of the responsibilities and future operating structure of her job function and it declined to comment about the payout. In interviews, Ms. Hohmann-Dennhardt defended the payout as fulfillment of her employment contract.

Timothy Van Dyck, a partner of the firm Bowditch & Dewey in the employment practice, said the severance package seemed “extraordinarily high,” even if part of it is due to a provision of her hiring contract related to a financial package she had received from a previous employer, as was reported. “The devil is in the details,” he said, about questions regarding the size of the payout. “If this represents part of a buyout regarding Daimler [her previous employer], it still seems extraordinarily high,” he said.

FUTURE WHISTLEBLOWER PAYOUT.   Moreover, said Mr. Van Dyck, Volkswagen can’t prevent Ms. Hohmann-Dennhardt from reporting to law enforcement what she saw while in her position at the firm. “It behooves companies to understand that even if there is a big payout…that doesn’t prevent them from going to a government agency if they think there’s been a violation of the law,” he said.