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Tip of the (compliance) hat to Hui Chen

Tom Fox | June 12, 2017

Hui Chen’s position has been listed to fill on the Department of Justice Website, so it appears her contract at the compliance counsel will not be renewed. Chen’s tenure as the Compliance Counsel has helped to raise the profile of the chief compliance officer within corporations and the corporate compliance discipline more generally. Obviously, the Justice Department has long emphasized the role of both the CCO and compliance function, but after Chen became the compliance counsel,  there were two significant changes in the discussion regarding those roles.

The first was in discussions with the Justice Department. Prior to Chen’s arrival, such both negotiations and substantive discussions with the Department were usually handled through outside counsel. With Chen in the room, these meeting began to include substantive discussions with CCOs about the robustness of their company’s compliance programs both at the time of the incident giving rise to the potential FCPA allegations...

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