The Ins and Outs of Recertifications for Government Contractors
Marti Arvin and Anthony Buenger on the CMMC Framework
Nonpublication Requests For Patent Applications: Disadvantages
SBA’s New WOSB / EDWOSB Certification Requirement and 8(a) Economic Disadvantage Criteria Revisions
Compliance Perspectives: Preparing for the Certification Exams
PODCAST: Williams Mullen GovCon Perspectives - Why Was My SWaM Certification Denied, and What Can I Do?
Making Effective Use of the Claims/Disputes Process
On December 16, 2024, the new Cybersecurity Maturity Model Certification (CMMC) 2.0 program from the U.S. Department of Defense (DoD) will go into effect. CMMC 2.0 aims to improve cybersecurity standards within the defense...more
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
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
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
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
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
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 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 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
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
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
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