Chief Compliance Officers Over a Barrel: Sign and Certify, or No Deal?
During a speech last month, Lauren Kootman, the Assistant Chief of the Corporate Enforcement, Compliance, and Policy Unit of the Fraud Section of the Department of Justice, signaled a daunting change for chief compliance officers. It was reported that Kootman touted a “likely” new requirement that would be incorporated into every corporate fraud settlement. This requirement would require CCOs to certify that the company’s compliance program was “reasonably designed” to prevent violations in the future. Kootman reportedly took the position that this would “empower” CCOs—giving them involvement in transactions and decision-making.
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