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How Hui Chen prompted an evolution in compliance at the DoJ

Tom Fox | August 1, 2017

With the departure of Hui Chen from her position as the Compliance Counsel at the Fraud Section of the Justice Department, now is a good time to consider how the focus of the Department around corporate compliance programs evolved during her tenure, culminating in the release of the Evaluation of Corporate Compliance Programs (“Evaluation”) document in February 2017.

Compliance program metrics

Chen came on board with the Justice Department in the fall of 2015 and almost immediately afterward, we saw a substantial release of information that the compliance practitioner could use in a best practices compliance program. The first instance was in a speech by then Assistant Attorney General Leslie R. Caldwell to the SIFMA Compliance and Legal Society New York Regional Seminar, in November 2015. Caldwell then went on to lay out the metrics under which she said Chen would consider on a variety of topics.

Policies and procedures: