Cybersecurity's Developing Role In FCPA Compliance
By Ryan Rohlfsen, Patrick Reinikainen and Daniel Flaherty ( January 11, 2019, 12:49 PM EST) -- While much attention has been paid to Deputy Attorney General Rod J. Rosenstein's Nov. 29, 2018, revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy,[1] other remarks by Rosenstein and Principal Deputy Assistant Attorney General John P. Cronan in November suggest that the U.S. Department of Justice may also be adapting FCPA enforcement principles to the area of cybersecurity, to encourage more coordination and collaboration with the private sector. This continues the trend from the DOJ speeches in March, July and September of last year,[2] in which the DOJ officials extended FCPA enforcement principles to other contexts, and encouraged open communication through the FCPA opinions procedure. This development in the cyber arena may carry significant implications for a wide range of industries that handle sensitive data, such as the technology, health care, and financial services sectors....
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