Cybersecurity's developing role in FCPA compliance

Table of contents

• Rosenstein and responsible encryption
• Cronan, the FCPA policy and the cyber arena
• Potential implications for cybersecurity compliance
• Like corruption, cybercrime is a global challenge
• Health care, financial services, technology companies and other carriers of sensitive data may face high compliance expectations
• Disappearing messaging carries continued risks
• Compliance and cybersecurity departments should be adequately staffed to assist in government investigations
• Adequate policies and procedures should account for misconduct by third parties
• Conclusion

Article summary

Law 360, Expert Analysis: While much attention has been paid to recent revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy, other developments suggest that the US Department of Justice may also be adapting FCPA enforcement principles to the area of cybersecurity, say attorneys with Ropes & Gray LLP.