Can Compliance Certifications Empower CCOs?

Should CEOs and CCOs be required to certify that a company’s compliance program is working as it intended at the end of a corporate resolution? That is the question Assistant Attorney General Kenneth Polite has put to the prosecutors in the DOJ’s Criminal Division. In two recent speeches, he floated the idea as a way to empower CCOs and other compliance officers while also helping to ensure they have access to data and other resources. This article investigates whether that is an achievable goal and whether the requirement would have unintended consequences. For more on compliance programs, see our two-part series “Thirteen Questions an Adviser’s Principals Should Ask Compliance”: Part One (Mar. 29, 2022); and Part Two (Apr. 5, 2022).

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