Making Sense of the DOJ’s New Statements on Disappearing Messaging Apps

The DOJ’s new document retention guidance concerning popular disappearing messaging apps, included in the Corporate Enforcement Policy, have left many companies worried and confused. During recent events hosted by ACI and PLI, Daniel Kahn, the Chief of the DOJ’s FCPA Unit and David Johnson, the Unit’s Assistant Chief, shared their takes on this important new development and responded to companies’ arguments that the policy was overly burdensome and unrealistic. We analyze their statements with input from defense counsel and provide practical advice on what companies can do now to protect themselves. See our three-part series on the DOJ’s FCPA Corporate Enforcement Policy: “What’s New and What’s Not” (Jan. 10, 2018); “How Important Is the Presumption of Declination?” (Jan. 24, 2018); and “Cooperation and Compliance Expectations” (Feb. 7, 2018).

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