Christine Wong and Jan Dobrosielski authored an article for the Daily Journal discussing comments made by the Department of Justice's Criminal Division Assistant Attorney General Kenneth Polite regarding corporate compliance, and how companies should empower Chief Compliance Officers to lead change.
"Polite has repeatedly sketched out the profile of his ideal CCO: impressive, informed, and empowered with resources and access to drive meaningful change within the company," the authors wrote. "How closely a company's CCO fits that profile will inform how the company itself will be viewed by Polite's Criminal Division."
They added: "Polite knows that the CCO is 'called upon to be a resource for information, an enforcer of law and policy, and somehow the primary architect of [a] company's ethical culture.' It is therefore Polite's 'expectation,' as he told the audience at an American Health Law Association conference in Baltimore, that CCOs have 'a seat at the table,' and 'true independence, authority, and stature within their organizations.'"
"Polite believes that prosecutions alone cannot ensure public safety or good corporate governance. Rather, Polite's 'ultimate goal is to prevent corporate crime in the first instance,' 'both by holding individual wrongdoers accountable and by creating an enforcement regime that incentivizes responsible corporate citizenship.' CCOs have a 'powerful role' in crafting such a culture, and Polite would like to see them be empowered with the tools they need to effect such change."
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Originally published by Daily Journal
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