evaluation of corporate complaince programs Archives

13 Oct, 2024

Episode 340 — DOJ Updates Evaluation of Corporate Compliance Programs

The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that provides important direction on the design and implementation of an effective compliance program. DOJ understands the importance of this document. In recognition of evolving technology and compliance program innovations, DOJ updated its guidance to...

Electronic Communications Risks — DOJ Enters the Fray in March 2023 (Part II of III)

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18 Oct, 2023

Electronic Communications Risks — DOJ Enters the Fray in March 2023 (Part II of III)

Just to play devil’s advocate (or perhaps to push my agenda), I have conflicting views on corporate use of ephemeral messaging applications. On the one hand, I understand the importance of managing electronics communications data, prioritizing the preservation of relevant data, and reducing attendant costs from managing ever-growing amounts of electronic data. On the other hand, as a former prosecutor and now defense counsel, I...