The discussion of compliance programs has seen significant progress over the past year.For example, in September 1, Ms. Lisa Monaco of the U.S. Department of Justice (DOJ) updated its policy on responding to corporate crimes, and in March 2022, the DOJ's Criminal Division issued an "Evaluation of Corporate Compliance Program ( Evaluation of Corporate Compliance Programs” has been updated.
Among these trends, one point that Japanese companies should pay particular attention to is the discussion on voluntary disclosure to the authorities.In addition, the Compensation Incentives and Clawbacks Pilot Program announced by the DOJ's Criminal Division in March 2023 seeks to recover compensation/salaries from officers and employees who have been involved in fraud or failed to supervise it, and is of interest to companies. can be said to be a high topic.
Furthermore, with the evolution and diversification of business communication tools, it is becoming increasingly important for fraud investigations to protect and investigate communications on the personal devices and message platforms of executives and employees. Considering these factors, the investigation of personal devices, especially in cross-border cases, has become an unavoidable point of contention.
Focusing on these topics, this seminar will touch on the latest discussions surrounding compliance programs and explain the necessary preparations for Japanese companies and compliance initiatives that utilize data technology.