Davis Polk partner Dan Kahn was profiled in the September 2024 issue of Compliance & Ethics Professional Magazine. In the Q&A, Dan discusses his experience at the Department of Justice as a trial attorney in the Fraud Section and later as the Criminal Division’s acting deputy assistant attorney general. He provides insights on working with compliance teams as a prosecutor, the DOJ’s updated criteria for evaluating compliance programs, and the Foreign Corrupt Practices Act (FCPA) and other anti-corruption dispositions.

Dan served for 11 years in senior roles at DOJ and played a central role in developing enforcement policies on the FCPA, corporate enforcement, compliance and monitors.

When asked how he predicts the compliance and enforcement environment will evolve over the next five years, Dan said, “Enforcement trends have remained fairly constant over time. But I do think that technology – including artificial intelligence and methods of communication – will pose both a significant opportunity for compliance programs and enforcement efforts but also tremendous obstacles and challenges. I do not see a good solution to using off-system communications and messaging platforms by employees intent on committing crimes.”

Read the full article

Copyright [2024] CEP Magazine, a publication of the Society of Corporate Compliance and Ethics (SCCE). 

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