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On Sept. 7, 2017, Equifax Inc. announced to the world that from May 2017 through July 2017, it had experienced a cyberattack that had compromised the security of the personal information of 145.5 million U.S. consumers. Equifax's initial offer to provide affected individuals with a year of its own credit monitoring service in response was met with skepticism and downright incredulity by those who maintained that the suggested “fix” was hardly enough to compensate consumers for the fallout they were bound to experience as a result of the incident.
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
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