Compliance officers will see plenty of headlines today about James Comey, newly confirmed director of the Federal Bureau of Investigation. In that capacity, his name is good to know because he’ll be the one in charge of the agents who might be kicking down your warehouse door some day during a misconduct investigation. But Comey’s name should also ring other bells from those early days of the compliance revolution in the 2000s.
Comey was U.S. attorney for the Southern District of New York in 2002 and 2003, and then deputy attorney general under the Bush Administration from 2003 to 2005. In the latter capacity he oversaw all of the Justice Department’s prosecutions for corporate misconduct, and he was one of the first deputy AGs to start scaling back the Thompson Memo, an unpopular Justice Department missive from 2003 that set stern cooperation criteria for companies under investigation if those companies ever hoped to avoid indictment.
