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, resolutions with U.S. enforcers often include ongoing requirements that mean companies must mind their manners with the SEC and DOJ 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 post-resolution life. This article summarizes the key takeaways, including with whom the DOJ wants to speak over the term of the settlement, and the benefits of realism and accountability in those interactions. See our three-part series on root-cause analysis: “DOJ Expectations and Getting to Why” (Jun. 23, 2021), “Gathering Information” (Aug. 4, 2021), and “Touching Bottom and Advanced Maneuvers” (Aug. 18, 2021).

To read the full article

Continue reading your article with an ACR subscription.