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In recent months, the U.S. Department of Justice (DOJ) has raised expectations for companies to use data analytics to monitor the effectiveness of their compliance programs and to identify potential misconduct. By its terms, data analytics is the process of analyzing raw data in order to discover useful information to inform conclusions and decision-making. The DOJ has increasingly used data analytics to identify potential wrongdoing and has recently sent the message that it expects companies to follow suit and incorporate data analytics in their compliance programs. In June 2020, the Criminal Division of the DOJ issued revised guidance (June 2020 Guidance) about how it will evaluate corporate compliance programs, and it included specific references to the use of data analytics. U.S. Dep’t of Justice, Criminal Div., Evaluation of Corporate Compliance Programs (June 2020).
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DOJ’s Cyber Fraud Initiative: A Wake-up Call That Keeps Ringing
By Randy S. Grossman, Kareem A. Salem and Kayla LaRosa
DOJ’s Cyber Fraud Initiative has been a wake-up call for companies to prioritize cybersecurity and adhere to stringent standards. By leveraging the FCA, DOJ has used a powerful enforcement tool to target a wide range of cybersecurity failures and misrepresentations. The increasing focus on cybersecurity by enforcement agencies means that robust cybersecurity practices are becoming a standard expectation, not just a best practice.
The State of Supreme Court Jurisprudence On Public Corruption
By Carrie H. Cohen and Allison M. Magnarelli
In the past decade, each time the Supreme Court has taken certiorari in a public corruption case, the court has reversed trial convictions and limited the types of conduct that constitute a federal bribery offense.
Defending Against Extradition to the United States
By Robert J. Anello and Richard F. Albert
The arm of U.S. extradition law is long. Fortunately, practitioners have defenses at their disposal that they may raise in the requested country’s courts to help either limit the scope of prosecution once extradition occurs, or to prevent it altogether.
New DOJ Self-Disclosure Pilot Program Increases Risk for Startups
By Jonathan Fahey, Jonathan P. Lienhard and Oliver Roberts
The DOJ has created new incentives for employee, or anyone, to report criminal misconduct allegedly committed by companies and their agents. Given their often laxer internal reporting structures and higher employee turnover rates, startup companies should pay particularly close attention to this new development to best mitigate legal risks.