Examining New DOJ Compliance Counsel Hui Chen’s Four Elements of a Successful Compliance Program

Hui Chen, the first-ever compliance counsel to the Fraud Section at the DOJ, described her new role as a “bridge between the compliance community and the prosecutors at the Fraud Section” in remarks at the ACI FCPA Conference shortly after she started at the DOJ in late 2015. The former prosecutor and compliance officer outlined the elements of a healthy compliance program that she will be looking for as she makes her assessments. The Anti-Corruption Report discussed these elements with experts who have both in-house and prosecutorial experience to determine the reasonableness of these expectations and what else companies need for a strong program. See “DOJ Compliance Counsel Hui Chen Is on the Job and Looking for Key Aspects of Strong Compliance Programs” (Nov. 18, 2015).

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