All of this leads me to conclude the DOJ (as well as the Securities and Exchange Commission (SEC)) want to see compliance moved out into the business. This means that Chief Compliance Officers (CCO’s) will need to move past the thinking that simply having a compliance program will be enough to make compliance effective. You must actually be doing compliance going forward. So what are some of the indicia of doing compliance as a business?
‘Enforcement 40’ for 2020
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