Financial fraud, health care fraud, consumer fraud, and fraud against the government are just a few areas of continued enforcement focus for the Department of Justice heading into 2019. But at the center of it all, 2019 also has the potential to be the year of the compliance officer.
If companies take just one message from the public remarks of enforcement officials over the past year as it concerns white-collar criminal enforcement, it’s that compliance officers and in-house counsel, more than anybody else, are on the front lines of promoting ethical cultures and detecting, deterring, and remediating misconduct. That is precisely why they are looked upon by the Department as valuable partners, not adversaries.
“It is often you who will confront difficult decisions about how to respond to bad actors; what compliance, audit, and ethics programs will look like; what resources will be devoted to those programs; and the level of access that compliance personnel will have...