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The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

June 30, 2022 | Compliance Monitoring Risk + Compliance

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs are effective.

Instead, a warm productive sunlight will shine upon CCOs and companies. That’s because these CEO / CCO certifications – if done well with independent validation – will empower the CCO while holding the CEO, C-suite, and their business executives more accountable for their conduct and compliance.… Read More

DOJ’s Use of Data Analytics for Prosecutions Becomes the “Norm”

October 7, 2019 | Compliance

The Fraud Division of the U.S. Justice Department unsealed an indictment recently that charged three traders associated with a global U.S.-based bank with a racketeering conspiracy that involved alleged manipulation of the precious metals markets through “spoofing.” The indictment alleges numerous specific instances of spoofing, over an approximately eight-year period, intended to improperly affect prices for precious metals and related options. The U.S. Commodity Futures Trading Commission filed a parallel civil action against the three traders as well, likewise charging … Read More

How The DOJ’s New Guidelines on Monitorships Is an Opportunity for Corporations

October 23, 2018 | Monitoring

Navigating new criminal division guidance and accelerating remediation

As published in Corporate Compliance Insights on October 23, 2018.

In his remarks at the Corporate Compliance and Enforcement Conference last Friday, Assistant Attorney General Brian A. Benczkowski expanded on the Department of Justice’s (DOJ) new guidelines for corporate compliance and monitorships, issued on October 11, 2018.

While it is yet to be seen how these new guidelines will impact the frequency of monitorships, it does seem clear that the DOJ … Read More

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