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    Jul. 16, 2025

Do the 2025 Changes to the DOJ’s CEP and Whistleblowing Programs Encourage Companies to Self-Report?

When President Donald Trump and AG Pam Bondi took office, it was immediately clear that there would be changes to DOJ enforcement priorities, but the fates of programs aimed at convincing companies and people to alert the DOJ when they discover wrongdoing were less certain. Adding some clarity to the landscape, DOJ Criminal Division Head Matthew Galeotti has announced changes to several key Criminal Division policies, including the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and the DOJ Corporate Whistleblower Awards Pilot Program (WAPP). This article examines the changes to the CEP and WAPP – the policies most likely to influence self-reporting and whistleblowing - and how they might impact a company’s decision to turn itself in when a crime is identified. See “Assessing the Criminal Division’s New Enforcement Focuses” (Jun. 18, 2025); and “Assessing the Criminal Division’s 2025 Take on Compliance Monitors” (Jul. 2, 2025).

Holding the Line: Evolving ABAC Practices in a Changing World

For many years, lawyers who specialized in anti-bribery and corruption (ABAC) were slowly putting themselves out of a job by helping to change global attitudes toward graft, but the tides have changed and the future of ABAC compliance and enforcement is less clear. In this guest article, William Semins, a partner at K&L Gates, discusses how the landscape has shifted over the last two decades, how the jobs of ABAC experts have changed in response and what the future might hold for those in the field. See this two-part series on the FCPA Executive Order: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).

Why Modern Corporations Need Investigative Memory

Many in the compliance space have been focused on the potential for technology to improve compliance program efficiency and effectiveness. In particular, there is significant potential for data analytics, machine learning algorithms and artificial intelligence to detect patterns of misbehavior across an organization. However, the most sophisticated pattern recognition systems remain limited by the silos, cognitive biases, staff turnover effects and information architecture problems that fragment institutional knowledge. In this guest article, Anurag Jain, a financial fraud investigator and certified fraud examiner at Van Dermyden Makus Law, who is also the CEO of EntityVector and RiskPulse AI, discusses why organizations must address these structural barriers before technology can unlock the full potential of their investigations. See “2024 in Review: Industry Sweeps and Data Analytics to Find Cases” (Jan. 29, 2025).

Cybersecurity and AI Are Top Global Business Challenges Identified in Kroll Study

Business professionals from more than 20 countries identified cybersecurity and AI integration as their most pressing challenges, according to Kroll’s 2025 Global Business Sentiment Survey. Kroll asked respondents about how they are approaching uncertainty and upheaval around the globe, and their perspectives on key challenges and risks, including economic instability, data privacy and geopolitical and trade risk. This article synthesizes the survey results and insights shared by Kroll leaders during an online program on key findings from the survey, strategies for mitigating the identified risks, and approaches to governance and compliance. See “In-House Perspectives on Compliance’s Role in Managing New and Emerging Risks” (May 22, 2024).

Decoding the Administration’s First Cyber Executive Order

A cybersecurity executive order (EO) issued by President Trump last month rescinds an entire section on digital identity and softens several detailed requirements set forth in former President Joe Biden’s last-minute cybersecurity order from January. Yet, the EO retains many of Biden’s directives for agencies and businesses that work with them. This article highlights the EO’s most important changes, the administration’s effort to influence private sector cybersecurity through government procurement practices and the federal cyber policy priorities that businesses should heed, with insights from cyber practitioners at Goodwin, Holland & Knight, the Linux Foundation and Venable. See “Reference Guide to 2025 Executive Orders for Compliance Professionals” (Apr. 9, 2025).

Greg Bates Goes In House to Aduna Global

A former member of Miller & Chevalier, Gregory Bates has joined global communications technology company Aduna Global in Washington, D.C. He will lead the company’s ethics and compliance program. For commentary from Bates, see “High Risks, Low Institutional Trust: Why Stronger Anti‑Corruption Laws Do Not Guarantee Increased Reporting of Corruption in Latin America” (Aug. 14, 2024)

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.