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Law firms are spending record amounts on technology right now. According to HSBC’s latest survey, the average firm is investing 6.5% of annual revenue — more than ever before (see, HSBC & Briefing, Law Firm Strategy and Investment Survey 2025/26). Cloud migrations are accelerating. Legacy applications are being consolidated. Digital capabilities are expanding across every practice area — and of course, AI investments.
Gartner recently predicted that over 40% of advanced technology projects will be canceled by 2027 (see, “Gartner Predicts Over 40% of Agentic AI Projects Will Be Canceled by End of 2027” (June 2025)). Not because the technology is bad, but because integrating new systems into existing operations is far more complex than most organizations anticipate. Workflows get disrupted. Costs spiral and promised benefits never materialize.
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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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