CCOs and Criminal Cartel Compliance Programs (Part II of III)
Chief compliance officers have plenty of things to do and risks to manage. CCOs have a unique remit and a set of skills that should be applied whenever needed. While I am not trying to increase CCO workload (and forgive me if I am), CCOs should have responsibility for design and implementation of an effective criminal antitrust compliance program. For many years, antitrust compliance was...