Acting Fraud Section Chief Dan Kahn Shares Insights on How the DOJ Thinks About Compliance

Noting that “in many ways, compliance has to be much more diligent than normal” during the pandemic, Acting Chief of the DOJ’s Fraud Section Daniel Kahn acknowledged that budget cuts and the vagaries of remote work pose new challenges for corporations as they continue to implement their compliance programs. Speaking at SCCE’s first Corporate Compliance Enforcement Conference, Kahn, in a one-on-one panel with William Jacobson, a partner at Allen & Overy, emphasized the importance of continuous evolution, both in addressing changes organizations may have had to make to their compliance programs during the pandemic and in making adjustments to compliance programs more generally. We summarize the key takeaways from the discussion. See our two-part series on updates to the ECCP: “Encouraging Companies to Make Compliance a Positive Feedback Loop” (Jun. 24, 2020); “Providing More Nuance on Training, M&A and Third-Party Management” (Jul. 8, 2020).

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