Welcome to the Hughes Hubbard Anti-Corruption and Internal Investigations Practice Group’s Podcast, All Things Investigations. In this podcast, returning guest Kevin Abikoff of the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group and I highlight some of the key legal issues in white-collar investigations, locally and internationally, and Chief Compliance Officer Certification Requirements.
Kevin Abikoff is partner, deputy chair at Hughes Hubbard, and Chairman of the firm’s See more +
Welcome to the Hughes Hubbard Anti-Corruption and Internal Investigations Practice Group’s Podcast, All Things Investigations. In this podcast, returning guest Kevin Abikoff of the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group and I highlight some of the key legal issues in white-collar investigations, locally and internationally, and Chief Compliance Officer Certification Requirements.
Kevin Abikoff is partner, deputy chair at Hughes Hubbard, and Chairman of the firm’s Anti-Corruption & Internal Investigations Practice Group. He specializes in securities, and white-collar criminal litigation, enforcement, regulation, and counseling, emphasizing the representation of entities in anti-corruption (including FCPA) matters.
Key ideas we discuss in this podcast:
1. The DOJ has instituted a new requirement for CCOs to certify that their programs are “reasonably designed” to detect and prevent law violations.
2. The potential for liability as a CCO.
3. How this new requirement may pressure CCOs to go beyond their usual duties to make the certification.
4. Corporate governance as a remediation of the CCO certification requirement.
5. The board of directors should be responsible for overseeing corporate compliance programs rather than just nominally doing so.
6. The DOJ listens to commentators and evolves in their thinking.
KEY QUOTE:
“Part of the narrative [for CCO certification] is that it gives CCOs a seat at the table. If you don’t have a seat at the table after you've gone through an FCPA enforcement action, I think there are bigger problems.” - Kevin Abikoff See less -
