News & Analysis as of

Department of Justice (DOJ) Certification Requirements

Womble Bond Dickinson

With Great ‘Empowerment’ Comes Great Responsibility (and Risk) for CCOs Under Monaco Memo

Womble Bond Dickinson on

The Monaco memo’s imposition of CCO certification in DOJ investigations has, reasonably, been a major anxiety-inducer for compliance professionals. And while DOJ officials have said the requirement is designed to “empower”...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

Womble Bond Dickinson on

Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

Latham & Watkins LLP

US Government Uses Receipt of PPP Funds to Create Piggyback Liability in FCA Case

Latham & Watkins LLP on

Physician Partners of America’s settlement highlights significant risks facing False Claims Act defendants who received Paycheck Protection Program funds. An April 2022 US Department of Justice (DOJ) settlement suggests...more

BakerHostetler

DOJ Corporate Compliance Certifications Appear to Be Here to Stay

BakerHostetler on

The compliance certification policy was first announced by Assistant Attorney General (Assistant AG) Kenneth Polite in March 2022, when he stated that for all criminal division “corporate resolutions (including guilty pleas,...more

American Conference Institute (ACI)

DOJ CCO Certification Requirement Will Up the Ante of CCO Oversight

Officials with the U.S. Department of Justice have portended a sea change in the oversight responsibilities of chief compliance officers (CCOs) as it concerns corporate resolutions going forward. In public remarks made March...more

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

Dechert LLP on

Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

Eversheds Sutherland (US) LLP

DOJ to place additional burdens on CCOs

Last week, yet another US Department of Justice (DOJ) official reportedly stated new corporate settlements “most likely” will include a requirement that the company’s chief compliance officer (CCO), as well as the chief...more

The Volkov Law Group

CCOs and Execution of Compliance Certification: A Significant Risk? (Part III of III)

The Volkov Law Group on

CCOs, by definition, are careful and deliberate.  It comes with the profession.  As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment....more

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

The Volkov Law Group

DOJ Compliance Program Certification Requirements (Part I of III)

The Volkov Law Group on

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to...more

The Volkov Law Group

DOJ Criminal Division AAG Underscores Role of CCOs and Announces CCO Certification Requirements

The Volkov Law Group on

In a homecoming speech, DOJ’s Assistant Attorney General Kenneth Polite gave a rousing speech to a room full of compliance professionals at the annual Compliance Week meeting in Washington, D.C.  AAG Polite, who has served as...more

Venable LLP

New Certification Requirements on the Horizon for CCOs: Certifying the Efficacy of Compliance Programs at the Conclusion of...

Venable LLP on

On Tuesday, March 22, 2022, Assistant Attorney General Kenneth Polite of the Department of Justice (DOJ) told an audience of compliance professionals that DOJ will direct prosecutors to "consider requiring" chief compliance...more

Wiley Rein LLP

ATF Issues New Rule Amending Secure Gun Storage Requirements

Wiley Rein LLP on

On January 4, 2022, the Department of Justice (DOJ) announced a new rule governing secure storage requirements for federal firearms licensees (FFL). The new rule goes into effect on February 3, 2022. DOJ also announced that...more

Bradley Arant Boult Cummings LLP

Continuing Effort to Protect National Security Data and Networks

CMMC 2.0 – Simplification and Flexibility of DoD Cybersecurity Requirements - Evolving and increasing threats to U.S. defense data and national security networks have necessitated changes and refinements to U.S. regulatory...more

Holland & Knight LLP

False Claims Act Meets Cybersecurity: DOJ's New Civil Cyber-Fraud Unit

Holland & Knight LLP on

Earlier this week, the U.S. Department of Justice (DOJ) announced the launch of its new Civil Cyber-Fraud Initiative — an effort designed to harness the department's knowledge in civil fraud enforcement, government...more

Dorsey & Whitney LLP

False Claims Act Case Tracker for Paycheck Protection Program Fraud - Update

Dorsey & Whitney LLP on

In the Spring of 2020, the Small Business Association (“SBA”) began administering the Paycheck Protection Program (the “PPP” or the “Program”) to provide SBA-backed loans to help eligible businesses maintain their workforces...more

Pillsbury Winthrop Shaw Pittman LLP

Developments in Association Law 2019 – 2020

A review of key legal developments for nonprofit organizations at the federal and state levels in 2019 and 2020. Antitrust enforcement continues against nonprofits. Nonprofits have litigated in other areas, including...more

The Volkov Law Group

Preventing Terrorism with AML Accountability AND Budgeting

The Volkov Law Group on

Preventing money from getting to terrorists is a chief goal of AML programs. But at a basic level an AML program is only as strong as its budget, regardless of how good the CCO is. Can we hold CCOs criminally accountable for...more

18 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide