electronics communications policies Archives - Corruption, Crime & Compliance

19 Oct, 2023

Practical Steps to Mitigate Electronics Communications Risks: “This is the Way” (Part III of III)

I always welcome any chance to use references to The Mandalorian series on Disney (or Ashoka for that matter) in the compliance arena. My take on the issue of electronic communications and ephemeral messaging is rooted in practical, risk-based strategies to avoid potential legal consequences that appear to be steadily growing as DOJ and courts deal with the issues. So, “This is the Way,” at...

General

17 Oct, 2023

Electronic Communications Risks — Asking the Critical Questions? (Part I of III)

Honestly, I have been avoiding this topic since it presents a real morass of risks and potential traps for the unwary company and Chief Compliance and Chief Legal Officers. When I first examined the issue, I understood DOJ’s frustration. If bad actors can escape detection and subsequent punishment (internal or external) by using ephemeral messaging applications to delete illegal or improper communications, companies should simply...