Davis Polk partner Dan Kahn was quoted in Anti-Corruption Report on enforcement trends, data analytics and highlights from Corporate Criminal Investigations and Prosecutions, a book which Dan co-authored. Dan noted that the book addresses “areas that are driven by practice and where there is not a lot of guidance – internal investigations, government investigations, multi-jurisdictional investigations, corporate resolutions, compliance and monitorships.”

When asked about trends he expects to see this year, Dan explained that he does not think corporate enforcement as a whole will rise substantially, despite the DOJ’s comments citing new “red tape” among other factors.

On the subject of data analytics, Dan said, “The DOJ and SEC, however, do not expect every company to have an extensive data analytics program,” Kahn emphasized. “That is not for everyone both from a resources standpoint and a functionality standpoint, but every other piece of the compliance program hinges on whether the company is able to track its data so that it can take a risk-based approach and evaluate whether or not it has allocated resources appropriately.”

“Insiders Tsao, Soltes and Kahn Share Insights on Investigations,” Anti-Corruption Report (January 4, 2023) (subscription required)

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