DOJ Further Revises Corporate Criminal Enforcement Policies: Focusing on Individual Accountability, Corporate Responsibility, and Additional Demands on Chief Compliance Officers
Health Law Advisor
OCTOBER 5, 2022
Thus, she emphasized that “if a cooperating company discovers hot documents or evidence [during a government investigation], its first reaction should be to notify the prosecutors.”. that the compliance program is “reasonably designed and implemented.”. This may have a chilling effect on companies seeking to retain qualified CCOs.
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