Client Alert: DOJ Initiatives Aim to Empower Chief Compliance Officers and Strengthen Corporate Compliance Programs

On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing initiatives that DOJ is undertaking regarding corporate compliance programs and Chief Compliance Officers (CCOs). AAG Polite anchored his remarks in his own experience as a former Chief Compliance Officer at Entergy. He emphasized that the goal of these initiatives is to improve the stature of CCOs, help ensure CCOs can express concerns, and try to ensure CCOs feature prominently in an organization’s remedial efforts. The initiatives include:
  1. Asking Criminal Division prosecutors to consider requiring as part of corporate resolutions that CEOs and CCOs certify at the end of the resolution term that the company’s compliance program is reasonably designed and implemented to detect and prevent violations of law; and
  2. “Revamping” the Fraud Section’s former Strategy, Policy, and Enforcement Unit into a newly named Corporate Enforcement, Compliance, and Policy (“CECP”) Unit that includes new management and former compliance and defense lawyers with experience in compliance, monitorships, and corporate enforcement.

Read the full alert here.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: DOJ Initiatives Aim to Empower Chief Compliance Officers and Strengthen Corporate Compliance Programs
On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing initiatives that DOJ is undertaking regarding corporate compliance programs and Chief Compliance Officers (CCOs). AAG Polite anchored his remarks in his own experience as a former Chief Compliance Officer at Entergy. He emphasized that the goal of these initiatives is to improve the stature of CCOs, help ensure CCOs can express concerns, and try to ensure CCOs feature prominently in an organization’s remedial efforts. The initiatives include:
  1. Asking Criminal Division prosecutors to consider requiring as part of corporate resolutions that CEOs and CCOs certify at the end of the resolution term that the company’s compliance program is reasonably designed and implemented to detect and prevent violations of law; and
  2. “Revamping” the Fraud Section’s former Strategy, Policy, and Enforcement Unit into a newly named Corporate Enforcement, Compliance, and Policy (“CECP”) Unit that includes new management and former compliance and defense lawyers with experience in compliance, monitorships, and corporate enforcement.

Read the full alert here.

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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