In the News

DOJ Rolls Back Ban On Disappearing Messages, Law360

Monday, March 11, 2019

In this Law360 article partner David Miller comments on changes the US Department of Justice announced to its Foreign Corrupt Practices Act corporate enforcement policy on March 15, 2019. The changes require companies to place controls on the internal use of disappearing messaging services. The policy now calls on companies to implement “appropriate guidance and controls on the use of personal communications and ephemeral messaging platforms that undermine the company’s ability to appropriately retain business records or communications or otherwise comply with the company’s document retention policies or legal obligations.” “Having those policies memorialized in the Justice Manual rather than in verbal remarks is essential for defense practitioners to be able to counsel their clients,” David said.

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