5 Tips For Meeting DOJ's New CCO Certification Requirements

By Jonny Frank, Laura Greenman and Chris Hoyle (June 30, 2022, 4:05 PM EDT) — In March, the U.S. Department of Justice Criminal Division Assistant Attorney General Kenneth Polite announced plans to require chief executive officers and chief compliance officers to certify to the effectiveness of the ethics and compliance program, particularly when the government does not impose a corporate monitor.[1]

The May Foreign Corrupt Practices Act plea agreement in U.S. v. Glencore International AG, in the U.S. District Court for the Southern District of New York, makes good on that plan and requires the CEO and CCO to certify the company met its compliance obligations under the agreement.[2]

Similarly, the April deferred prosecution agreement in U.S. v. Stericycle Inc., in…

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