Michael Peregrine wrote this bylined article on the board governance implications of several new, highly publicized fraud enforcement initiatives by the Justice Department. Because the initiatives “directly implicate” board compliance obligations, Mr. Peregrine wrote, “the board is well advised to direct the general counsel to lead the organizational response to the new DOJ initiatives. The general counsel would then be expected to work collaboratively and cooperatively with the chief compliance officer, as a valued organizational partner.”
