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Compliance Department of Justice (DOJ) Certification Requirements

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
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

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

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

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

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