Being a chief compliance officer is no easy task these days. Trying to interpret the many mixed messages from government enforcement authorities regarding potential personal liability for compliance officers could be a full-time job. The perfect storm of the Yates Memo’s promise of enhanced individual prosecutions, recent indictments and sanctions of corporate compliance officers, followed by the U.S. Department of Justice’s appointment of its first compliance counsel has reverberated throughout compliance departments with a hair-raising echo.

In contrast, Assistant Attorney General Leslie Caldwell attempted to calm the storm by professing that the DOJ is not looking to prosecute compliance professionals. The chief of the Criminal Division’s fraud section, Andrew Weissmann, reaffirmed this point at the 2016 Compliance Week conference with a direct statement that the DOJ is not targeting compliance officers.

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