Issues Confronting Responsible Corporate Officers in the New Era of Government Food & Drug Enforcement

Issues Confronting Responsible Corporate Officers in the New Era of Government Food & Drug Enforcement
Christopher R. Hall, Gregory G. Schwab, Co-authors
White Collar Crime Committee Newsletter

Christopher R. Hall, chair of the White Collar and Government Enforcement Practice Group and Gregory G. Schwab, associate in the Litigation Department, published this article in the Summer 2011 issue of the White Collar Crime Committee Newsletter, a publication of the ABA. It serves as a guide for practitioners as to whether current compliance processes meet the governance obligations required by the Responsible Corporate Officer (RCO) doctrine, and the possible collateral consequences that may follow if they do not, as well as to help attorneys assess whether their clients' current compliance processes will adequately serve to avoid falling within this government initiative.