Kathleen McGovern

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DOJ Updates Ephemeral Messaging Guidance

On Friday, March 3, 2023, the DOJ released its updated Evaluation of Corporate Compliance Programs, which included new guidance on ephemeral messaging platforms and other issues. This new guidance was released contemporaneously with Assistant Attorney General Kenneth A. Polite, Jr.’s (‘Polite”) speech at the American Bar Association’s (“ABA”) 38th Annual National Institute on White Collar … Continue Reading

FTC Signals More Criminal Referrals for Negative Option Fraudsters

Our colleagues at Privacy World blog have been monitoring negative option marketing (or dark patterns) for some time.  Last week, the FTC delivered its 2022 Criminal Liaison Report where it detailed its success referring FTC consumer fraud cases to prosecutors for criminal prosecution.  Again, our Privacy World colleagues are there to discuss what this Report means … Continue Reading

DOJ’s Criminal Division Announces Revised Corporate Enforcement Policy

On January 17, 2023, Assistant Attorney General for the Criminal Division (“AAG”) Kenneth A. Polite, Jr. announced significant revisions to the U.S. Department of Justice, Criminal Division, corporate criminal enforcement policy (“CEP”).[1] The new CEP changes offer additional incentives to companies for voluntary self-disclosures, cooperation, and remediation.  The new CEP reflects an increased emphasis on … Continue Reading
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