The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.” While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine their authority by opening CCOs to internal pressure to execute a certification despite concerns about the status of a company’s compliance program. In this episode, Michael Volkov reviews DOJ’s new CCO certification requirement.
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