DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)
The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers. In Part I of this series, I outlined the specific language and the Plea Agreement standards imposed on companies that enter into a Plea Agreement with DOJ for FCPA violations. DOJ has reiterated its support for this new Certification requirement. Indeed, a DOJ official...