The newly released corporate compliance policies (“Compliance Policies”) announced by senior Department of Justice officials on March 2 and 3 significantly engage corporate leadership at several different levels.
This, perhaps more so than previous government corporate compliance initiatives, that focused broadly on the state of compliance program effectiveness. These latest Compliance Policies reflect specific DOJ initiatives that may require significantly more officer and director awareness and response than before. The organization’s Chief Legal Officer, perhaps teaming with the Chief Compliance Officer, is the logical executive to advise the board, its committees and executive leadership on the appropriate response to these new, significant Policies.
