Assistant Attorney General Kenneth Polite, leader of the Criminal Division at the U.S. Department of Justice, recently issued a warning to companies negotiating resolutions with federal prosecutors, stating that companies that bring in lawyers to advocate for a particular settlement should let their chief compliance officer take “a prominent role in those presentations."
Polite has shown a continued commitment to giving compliance executives greater authority to voice concerns internally about their company’s process for preventing misconduct. There's no “one-size-fits-all” guidance on how his department will evaluate corporate compliance programs to determine whether to bring charges or in reaching deferred prosecution agreements, but Polite did provide detail on the criteria DOJ lawyers consider.
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