On May 15, I informed the Fraud Section in the Criminal Division at the U.S. Department of Justice that I did not intend to renew my contract as its Compliance Counsel Expert. Last Friday, I officially ended that role.

Leaving DOJ was not an easy decision. Serving as the Fraud Section’s compliance counsel had given me not only the privilege of working with some of the most dedicated, intelligent, and innovative prosecutors in the federal government, it had also given me a platform from which I believed I could make a positive difference. Now, my reason for leaving is the same: to make a difference. For reasons articulated below, I believe the time has come when I can make a bigger difference outside of the DOJ than inside.

First, trying to hold companies to standards that our current administration is not living up to was creating a cognitive dissonance that I could not overcome. To sit across the table from companies and question how committed they were to ethics and compliance felt not only hypocritical, but very much like shuffling the deck chairs on the Titanic. Even as I engaged in those questioning and evaluations, on my mind were the numerous lawsuits pending against the President of the United States for everything from violations of the Constitution to conflict of interest, the ongoing investigations of potentially treasonous conducts, and the investigators and prosecutors fired for their pursuits of principles and facts. Those are conducts I would not tolerate seeing in a company, yet I worked under an administration that engaged in exactly those conduct. I wanted no more part in it.

Second, my ability to do good at a more micro-level, by exchanging ideas with the compliance community on ways to assess the effectiveness of compliance programs, was severely limited. The management of the Criminal Division, of which the Fraud Section is a part, has persistently prohibited me from public speaking. This inability to engage was particularly frustrating after the release of the Evaluations of Corporate Compliance document, as I watched almost everyone except me being able to talk about (and often misinterpreting) my work.

Third, I have come to realize that nothing matters to me more than working to restore the notions of integrity, decency, and intellect back into our government. I yearn to be a part of that effort more directly than volunteering for and attending protests: I want to help elect candidates who stand for those values, and I cannot do that while under contract with the Criminal Division due to Hatch Act restrictions.

The time I spent in the Fraud Section has been among of the most rewarding experiences in my career, and I cannot speak more highly of the prosecutors with whom I had the pleasure of working. I will miss them dearly, and I hope and pray that they remain in the government to protect and defend our Constitution and to hold corporations accountable. As a citizen advocate, I will also fight for resources and support for them to do their jobs.

What will I do now? The mission is the same: to make a difference. It seems clear that there is much work to do not only in taking corporate ethics & compliance to the next level, but also in raising the moral consciousness of societies. To those ends, I will engage publicly through speaking, writing, and consulting, working with not only corporations interested in enhancing their ethics & compliance programs, but also with foreign and domestic government agencies to enhance their leadership in the markets. I will also consider it my personal mission to participate in efforts to hold our elected representatives accountable and to protect our environment. I believe it has never been more important for every individual to speak and act on their conscience and belief.

We have just one life to live, and the mission we choose for that life matters as much as the life itself

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