CCO Certification of Compliance Programs

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take at the recent remarks by DOJ Assistant Attorney General Kenneth Polite on CCO certifications of compliance programs after the conclusion of a DPA. Highlights include:

·      Where did this issue come from?

·      Is its implementation looming?

·      What are the implications for individual CCO liability?

·       What about CEO liability for recidivism?  

·      What are the corporate governance implications?

Resources 

Text of Kenneth Polite speech

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