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DOJ Calls On Companies to Incorporate Data Analytics In Anti-Corruption Compliance Programs

By Fotis Konstantinidis, Michael Pace and Jason Wright
September 01, 2023

The U.S. Department of Justice's (DOJ) Foreign Corrupt Practices Act (FCPA) unit is cracking down on white-collar crime. To achieve this, the DOJ has recommended that companies incorporate data analytics to strengthen their compliance programs. Companies that heed this advice should implement a strong data analytics function, identify key risks and look to mitigate them.

This article explains the DOJ's recent emphasis on robust data analytics in anti-corruption compliance programs, outlines how data analytics can and should be used in these programs, and suggests an approach to help legal counsel and companies determine if corporate programs will pass muster with the DOJ.

The DOJ Has Been Clear On Data Analytics

The DOJ has already sent numerous signals that it sees data analytics as a crucial player in compliance programs. These signals include the DOJ's recent pronouncements, the hiring of Matt Galvin as compliance and data analytics counsel in the Criminal Division's Fraud Section, and its corporate enforcement policies.

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