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SEC and CFTC Continue Crackdown on Financial Firms Over Off-Channel Communications

Discovery Advocate

Employers should ensure that they maintain and consistently update policies and compliance procedures regarding record retention and the use of personal devices as regulators and prosecutors continue to focus on off-channel communications.

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‘Heed This Message’: Organizations That Fail to Contemplate Off-Channel Communications ‘Do So at Their Own Peril’

Discovery Advocate

In March, the DOJ Criminal Division revised its “Evaluation of Corporate Compliance Programs” (ECCP) guidelines , which prosecutors use to make corporate charging decisions, to incorporate those principles from the September 2022 Monaco Memo.

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Preparing for AI Whistleblowers

Debevoise Data Blog

Both increased regulatory scrutiny over AI use and record-breaking whistleblower activity has set the stage for an escalation of AI whistleblower-related enforcement. 3] Fiscal year (“FY”) 2022 and 2023 were each record-setting years for the SEC’s whistleblower program. To subscribe to the Data Blog, please click here.

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A New Era of FTC Privacy and Cybersecurity Oversight: Top Ten Things Companies Should Know When Assessing FTC Compliance and Exposure

Debevoise Data Blog

More recently, on January 4, 2022, the FTC issued an advisory informing companies of their obligation to remediate the Log4j security vulnerability and more generally ensure that security vulnerabilities are appropriately remediated. [13] 7, 2022). [14] FTC Publishes Inflation-Adjusted Civil Penalty Amounts for 2022 (Jan.