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What is the connection between #AI, the #FCPA and #anticorruption compliance? A few days ago, the U.S. Department of Justice announced an update of its guidelines for evaluating corporate #compliance programs. Among the most significant changes, the update included several new questions aimed at understanding how companies identify, assess and mitigate risks related to the use of AI and the company’s “ability to comply with criminal laws”. To my knowledge, this is the first policy document by an anti-corruption #enforcement agency to address AI #risks and compliance. Now, the DoJ could be expected to address the use of AI in corporate compliance programs at some point (for example, its use in monitoring expense report or to conduct #investigations). However, the guidelines go beyond that. In fact, the update raises issues on the use of IA in a company’s “commercial business”. It includes questions such as how a company manages risks related to the use of new technologies, how it prevents misuse or unintended consequences, what elements of human decision-making exist to assess AI risks, what #accountability mechanisms are in place, and whether the company offers training to its employees on the use such tools. This seems to be part of a worldwide trend to expand the notion of corporate integrity and the scope of corporate compliance programs to go beyond avoiding FCPA risks. The DoJ is once again leading the way. What other agencies will follow? https://lnkd.in/dPUtsqX5

Is AI the Future of Compliance? Breaking the Trust Barrier "I don't trust it."  "Too many hallucinations."  "Will it replace me??" These are common concerns compliance officers share when it comes to AI in regulatory processes. And it’s understandable—trust in AI-driven solutions takes time to build, especially in a field where precision and reliability are critical, and where a single oversight can have serious consequences. This brings up an important question: How can AI be trusted to handle complex regulatory frameworks when a compliance officer's expertise and intuition are so vital? The key lies in *how* AI is integrated into the process. AI isn’t here to replace compliance officers, but to empower them. Here’s why it can—and should—be trusted: ✅ AI Enhances Accuracy, Not Replaces It AI processes large volumes of data at speed, identifying gaps and ensuring nothing slips through the cracks. The best AI solutions are transparent, showing the decision-making process behind every recommendation, so compliance officers stay in control and make data-driven decisions with confidence. ✅ Compliance + AI = Human + Machine Collaboration Imagine having more time to focus on the strategic, high-impact work that really drives the business forward. AI can handle the repetitive, manual tasks—like document reviews, regulatory change analysis, or risk gap identification—so compliance officers can focus on the bigger picture without feeling overwhelmed. ✅ Building Trust Through Education & Involvement Trust in AI grows when compliance officers are actively involved in its deployment. Early adopters are already experiencing firsthand how AI can reduce risks, improve efficiency, and allow teams to focus on what matters most, without sacrificing control. When compliance officers understand how AI works, they not only trust it—they embrace it as a way to reduce stress and ensure nothing gets missed. Of course, change isn’t always easy. But in a world where regulations are evolving faster than ever, AI helps compliance teams stay ahead, reduce pressure, and focus on more fulfilling work. Those who embrace this change will find themselves better equipped to navigate today’s regulatory landscape with peace of mind. What’s your take? Have you started using AI in your compliance processes? I’d love to hear your experience. 👇

The Department of Justice recently released a new update to the "Evaluation of Corporate Compliance Programs." The revisions to the guidance highlight the importance of strong compliance programs that assess artificial intelligence risks, encourage “speak up” reports, utilize data to measure effectiveness, and more. For further insights on these topics and how the revised guidance may impact companies, read more: https://lnkd.in/gRNhPkRr Authors: Katya Jestin, David Bitkower, Erin R. Schrantz, Tali Leinwand, Idun Klakegg, and Ari Kanavy #DOJ #Compliance #AI #WhistleBlower

No time like the present to revisit your compliance program in light of DOJ’s latest update to its “Evaluation of Corporate Compliance Programs.” In addition to new content on AI and the compliance risks associated with other emerging technologies, compliance personnel should pay particular attention to how they are using data to measure the effectiveness and “stickiness” of compliance efforts to build a sustainable compliance culture.

🚨 Did you hear about the DOJ's AI addition to it's Corporate Compliance Program? Last week, the U.S. DOJ Criminal Division updated division policies on how companies manage risk related to AI. Prosecutors will evaluate how firms assess and manage the risks of new technology, including AI. ✅ The ECCP - Evaluation of Corporate Compliance Program Under ECCP - prosecutors will consider ➡ WHAT technology a company uses to conduct business ➡ WHETHER you conducted a risk assessment of that technology ➡ WHETHER you took appropriate steps to mitigate risk associated with that technology ✅ Are you monitoring and testing this technology? ✅ Is AI (or new technology) functioning as intended and in line with your code of conduct? ✅Do you have controls and tools to identify risks like ➡ "false approvals and documentation generated by AI" 💥 Note - these updates do NOT define core principles of AI compliance. 👉 They offer potential QUESTIONS that prosecutors may ask when evaluating your compliance program. 👉 EXAMPLE - how does your company assess the potential impact of new technology like AI on your ability to comply with criminal laws? 👉 EXAMPLE - how quickly can you detect and correct decisions made by AI or other new tech that are inconsistent with your company values? Compliance staff should have direct/indirect access to relevant sources of data so they can monitor policies, controls and transactions in a timely and effective way. Read 25 page PDF - U.S. Department of Justice Criminal Division Evaluation of Corporate Compliance Programs (Updated September 2024)  https://lnkd.in/eq-7ZCGJ

The latest updates to the DOJ's Guidelines for the Evaluation of Corporate Compliance Programs provide under-resourced compliance teams a strong platform to advocate for greater investment in both talent and tools. 👉 Read more about the updates in our latest blog post.

Peppermint Technology combines AI technological innovations with client-focused services to meet and surpass the demands of today’s legal environment. Our AI-driven solutions enable law firms to mitigate risks in several ways. John Ellis, Peppermint's account executive, has been featured in Briefing Legal, where he discusses strategies for mitigating risks associated with #AI implementation in law firms to ensure efficiency and compliance, paving the way for responsible and successful adoption. Click here to find out more: https://lnkd.in/eHEDy3Va Published in Briefing Magazine here: https://lnkd.in/eb6Ut5Ta #legaltech #briefinglive #generativeAI

The DOJ’s latest AI compliance guidance emphasizes the importance of continuous improvement. It’s crucial to ensure systems stay relevant and adapt to new risks over time, as outdated AI systems can pose serious threats. Regular updates are essential, especially with emerging ways to exploit AI technology.

Don’t fall behind on changes! The DOJ’s 2024 updates to its Corporate Compliance Program Guidance focuses on assessing risks of emerging technology like #AI, data use, the role of management, and more. You don’t have to play a guessing game, check out our latest blog for the details!  https://lnkd.in/e845FF4V

While these measures were effective historically, the advent of technology in financial services necessitates a reevaluation of how compliance oversight is conducted. The traditional tools, although useful, are limited by their episodic nature—real-time detection is often not feasible with existing methods. Saifr added that artificial intelligence could significantly change how compliance is managed and executed. Sophisticated AI tools could potentially function as around-the-clock virtual compliance officers, analysing data in real time and facilitating proactive compliance management with human oversight. For instance, consider the ethical obligations to assess conflicts arising from external business interests. The traditional reliance on employee self-disclosure limits a firm’s ability to uncover undisclosed conflicts or unauthorised activities. AI intervention could dramatically improve the firm’s capability to detect such issues. Furthermore, with the introduction of Reg BI in 2019, the requirements for overseeing securities recommendations have tightened, particularly with digital investment advice becoming more prevalent. AI-enhanced oversight could prevent lapses that periodic reviews might overlook. In scenarios like anti-money laundering, where episodic screening