News & Analysis as of

Chief Compliance Officers CEOs Department of Justice (DOJ)

NAVEX

From Healthcare Sector, a Big Push for CCO Autonomy

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For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more

Health Care Compliance Association (HCCA)

[Event] 2023 Healthcare Enforcement Compliance Conference - November 5th - 7th, Washington, DC

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us at HCCA’s Annual Healthcare Enforcement Compliance Conference to...more

Society of Corporate Compliance and Ethics...

[Webinar] Great Expectations: CEO and CCO Certifications of Ethics & Compliance Program Effectiveness - January 30th, 12:00 pm -...

Learning Objectives: - Participants will have a better understanding of how the CEO and CCO certification of compliance program effectiveness came to be. - Participants will learn about example cases where DOJ and SEC...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

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The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more

Guidepost Solutions LLC

Guidepost in Motion EP25: State of Compliance with Alixandra Smith Part 2

Eric T. Young and Alixandra Smith, deputy chief of the Criminal Division at the U.S. Attorney’s Office for the Eastern District of New York, continue their discussion about the Department of Justice’s expectations of...more

Paul Hastings LLP

Top PHive Crypto Enforcement Notes: September Edition

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Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...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

Paul Hastings LLP

Sign on the Dotted Line: Compliance Certifications by CEOs and CCOs A Likely Requirement

Paul Hastings LLP on

As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...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

Guidepost Solutions LLC

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more

Thomas Fox - Compliance Evangelist

Communication through persuasion

Even with this most turbulent year nearly at an end, we continue to lose many true greats. One of the greatest in baseball in the ‘60s and ‘70s was Richie (Dick) Allen. According to Tyler Kepner, writing in his On Baseball...more

NAVEX

[Virtual Conference] NAVEX Next: Beyond the Moment - October 22nd, 8:00 am - 2:00 pm PDT

NAVEX on

Register for NAVEX Next, our annual risk and compliance virtual conference. Formerly the Ethics & Compliance Virtual Conference (ECVC), the new name recognizes that we must be forward-looking as we face an increasingly...more

McDermott Will & Emery

Corporate Law & Governance Update - May 2019

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IMPORTANT BOARD COMPOSITION DEVELOPMENT - The board’s nominating committee will benefit from an overview of The Conference Board’s important new survey on board composition, turnover and refreshment. According to the...more

McDermott Will & Emery

First of Its Kind: Drug Wholesaler Accepts DPA and Two Executives Face Criminal Charges in SDNY For Illegal Distribution of...

On April 23, 2019, the US Department of Justice (DOJ) announced it has entered into a deferred prosecution agreement with Rochester Drug Co-Operative, Inc. (RDC), one of the 10 largest wholesale distributors of pharmaceutical...more

Foley & Lardner LLP

The Twelve Compliance Steps Every Multinational Corporation Should Undertake in Light of Recent Trump Administration Enforcement...

Foley & Lardner LLP on

Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more

McDermott Will & Emery

Corporate Law & Governance Update - June 2017

Board Termination of the "Unethical CEO" - An important new study concludes that CEO terminations for ethical lapses (as a percentage of overall CEO successions) has dramatically increased over the last five years. The...more

McDermott Will & Emery

Corporate Law and Governance Update - October 2016

McDermott Will & Emery on

New Officer and Director FCA/Stark Exposure - Recent developments may merit a measured briefing to corporate leadership on the potential exposure of health industry officers and directors to financial penalties and other...more

Thomas Fox - Compliance Evangelist

Want to Work in Compliance – Learn How to Read a Balance Sheet

One of the most interesting tag lines I heard at Compliance Week 2016 was the following, if you want to work in my compliance department; you need to learn how to read a balance sheet. I thought that single line encapsulated...more

Thomas Fox - Compliance Evangelist

The Dalton Gang’s Last Stand and What is a Conflict of Interest?

On this day in 1982, the fabled Dalton Gang rode into Coffeyville, Kansas, supremely confident in its ability to simultaneously rob two banks in the town. When the dust settled, four of the five gang members lay dead. The...more

Thomas Fox - Compliance Evangelist

Economic Downturn Week, Part III – The Desktop Risk Assessment

I continue my exploration of actions you can take to improve your compliance program during an economic downturn with a review of what my colleague Jan Farley, the Chief Compliance Officer (CCO) at Dresser-Rand, called the...more

The Volkov Law Group

A Neglected Compliance Task: Program Assessments

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The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx - Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their...more

The Volkov Law Group

Reactive Compliance: An Oxymoron?

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People make bad decisions. Companies make bad decisions. ...more

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