DOJ’s Precarious Plan to Trade Its Compliance Counsel for Internal Training and Expertise

The DOJ’s announcement in late 2018 that it has no plans to replace Hui Chen, the Department’s first compliance counsel who left the post nearly two years ago, was not “at all surprising,” Chen herself told the Anti-Corruption Report. In announcing its decision to do away with the role, the Department is merely “making formal what was already happening,” she argued. It was, however, still a disappointment for many in the compliance community. We discussed the decision with Chen and other DOJ alumni to explore inside perspectives on how it will impact FCPA enforcement. See “DOJ’s Focus on Compliance Expands Beyond the FCPA, Cronan Says” (Dec. 12, 2018).

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