New Certification Requirements on the Horizon for CCOs: Certifying the Efficacy of Compliance Programs at the Conclusion of Criminal Settlements
Assistant Attorney General Kenneth Polite told an audience of compliance professionals that DOJ will direct prosecutors to “consider requiring” CCOs and CEOs to certify at the end of a settlement term that “the company’s compliance program is reasonably designed and implemented to detect and prevent violations of the law and is functioning effectively.” This is the latest in a years-long trend of increasing expectations of compliance officers and their departments, and will be a significant area of focus in corporate resolutions in years to come. While in recent years corporations have elevated and recognized the importance of CCOs and the compliance function, this raises numerous concerns for both the CCO and the corporation.
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