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Jul. 6, 2022

Can Compliance Certifications Empower CCOs?

  • Megan Zwiebel
    Anti-Corruption Report
Should chief executive officers and chief compliance officers be required to certify that a company’s compliance program is working as intended at the end of a corporate resolution? That is the question Assistant Attorney General Kenneth Polite put to the prosecutors in the DOJ’s Criminal Division, and has now put into practice by including this requirement in recent FCPA Action. This article focused on two speeches in which he floated the idea as a way to empower compliance officers and ensure that they have access to data and other resources. We spoke to practitioners and investigated whether this is an achievable goal and whether there might be unintended consequences of such a requirement.

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