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    Jul. 2, 2025

Assessing the Criminal Division’s 2025 Take on Compliance Monitors

Imposition of an independent compliance monitor is one of the most dreaded outcomes for companies facing a DOJ investigation. While paying a fine or improving a compliance program may be expensive and burdensome, the company ultimately has some control in the matter. Monitors, on the other hand, “can create an adversarial relationship with the companies they monitor, impose significant expense, stray from their core mission, and unduly interfere with business,” DOJ Criminal Division Head Matthew Galeotti stated when announcing a memo changing when monitors will be required and how they will be regulated. This article, with insights from defense counsel and former DOJ prosecutors, examines these revisions, Galeotti’s statements about the changes, and what they might mean for companies facing Criminal Division investigations going forward. See “Adelle Elia of LBI Offers Insights on Working Effectively With a Monitor” (Jul. 24, 2019).

How the U.S. Focus on Cartels and Transnational Criminal Organizations Impacts Multinationals in Mexico

Companies operating in Mexico exist in an environment where cartels and drug trafficking pose persistent threats. Adding the risk of criminal prosecution to the mix for those companies, within its first months, the Trump administration has released multiple directives aimed at combating international criminal cartels. In this guest article, Miller & Chevalier members Maria Elena Lapetina and Katherine Pappas, with the assistance of visiting law clerk Manuela Jaramillo, discuss the Trump administration’s current approach to addressing cartel activity in Mexico; the intersection of shifting enforcement priorities and these cartel-related policies; and what companies operating in Mexico should be doing now to assess the potential impact of these initiatives. For more from Miller & Chevalier, see “Loose Lips Sink Ships: Maintaining Confidentiality in Investigations” (Nov. 20, 2024).

GCs’ Increasingly Critical Role in Managing Risk and Ensuring Compliance

As compliance requirements continue to evolve rapidly, the GC role has become more critical in avoiding regulatory entanglements and operational risks. Increasingly, in-house legal personnel are grappling with risk assessments, internal investigations, liaisons with regulators, strategic advice to executive staff and other areas not traditionally within the GC’s domain. This article, distilling insights and experiences shared by GCs and chief legal officers during the Compliance & Legal 2025 Annual Seminar, examines the growing internal and external responsibilities of the GC, including selecting and interacting with outside counsel. See “Lonza’s GC for Global Ethics and Compliance Discusses Enhancing a Compliance Program Post-Acquisition” (Feb. 6, 2019).

A Step-by-Step Approach to Upleveling Compliance Analytics

Many companies know that they could be making better use of their data to improve their compliance programs, but the process of making upgrades can be daunting. Ericsson, a Sweden-based telecommunication company, recently took a step-by-step approach to improve its data analytics program and prepare for the future, contemplating AI use. This article distills insights from three Ericsson compliance officers recently shared at the Society of Corporate Compliance and Ethics 2025 conference on Data Analytics for Compliance Programs. See “How Combining Approaches to Data Analytics Can Yield Powerful Insights” (Mar. 16, 2022).

Recognizing the Signs of Remote Employee Fraud to Save Money and Data

Companies face multiple risks from fraud at the hands of remote employees. For example, bad actors use fake identities and overseas proxies to gain access to sensitive information or siphon off money. To mitigate this growing threat, companies need to know how to vet employees at onboarding and monitor their activities. Distilling insights shared by AON and Ropes & Gray during a recent Privacy+Security Academy conference, this article examines the mechanics of employee fraud schemes and the risks they pose, and offers strategies to detect, prevent and investigate cases. See “Using the DOJ’s Compliance Evaluation As an Anti-Fraud Tool” (Sep. 15, 2021).

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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.