In this episode, I visit Mike Huneke, a partner at Hughes Hubbard. We look at the role of the GC in the CCO certification requirement as first announced by Assistant Attorney General Kenneth Polite and confirmed by Deputy Attorney General Lisa Monaco.
Key areas we discuss on this podcast are:
- What is the new CCO certification policy?
- Why did the DOJ create the policy?
- How has the DOJ’s thinking around recidivists evolved?
- Reasonableness is not a factual basis.
- Companies with full transparency are unlikely to have conflicts due to the recent changes in CCO certification.
- What is the role of the monitor going forward?
Resources
Mike Huneke on Hughes Hubbard
What is the General Counsel’s role in CEO and CCO compliance certifications? On the FCPA Blog
