Building an effective post-pandemic compliance program requires taking stock of, and acting on, US regulators’ shifting approach and priorities.
As detailed in a recent Latham Client Alert, the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC) have issued a number of policy updates and public pronouncements over the last several months, emphasizing the importance of empowered and accountable corporate compliance programs. US regulators clearly expect compliance programs to be empowered with sufficient resources, personnel, stature, and authority within their organizations to be effective, and they are looking to hold chief compliance officers (CCOs), so-called gatekeepers, and individual bad actors accountable for corporate compliance.
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