Meeting DOJ Expectations Post-Resolution Requires Realism and Accountability

Many companies think that settling an issue with the SEC or DOJ brings the matter to a close. However, the ongoing obligations that appear in numerous settlements require companies to mind their manners with U.S. enforcers for years after a deal is inked. In a recent panel hosted by Ethico, Sidley Austin partner and former Assistant Attorney General Kenneth Polite, compliance consultant and former DOJ Compliance Counsel Expert Hui Chen, and compliance consultant and former Albemarle CCO Andrew McBride discussed the intricacies and challenges of navigating the aftermath of regulatory resolutions. This article summarizes the key takeaways from the discussion, including who manages continued communications with the DOJ, how much to report and accountability. See “What CCOs Should Know About the DOJ’s Efforts to Curtail Criminal Use of AI” (Oct. 9, 2024).

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