Leveraging AI and Analytics to Streamline Compliance Investigations

On August 1, 2024, the US Department of Justice (DOJ) released the Corporate Whistleblower Awareness Pilot Program to incentivize whistleblowers to report corporate misconduct and, in turn, force organizations to strengthen their internal compliance programs and controls. The DOJ also announced an amendment to the Corporate Enforcement and Voluntary Self-Disclosure (VSD) Policy, whereby if a company receives a whistleblower report, it must complete its investigation and self-report to the DOJ within 120 days or lose eligibility for the protections of the VSD Program.

This development follows a global trend of increased whistleblower regulations, including the EU Whistleblower Directive and similar regimes in Japan and Australia. The EU Whistleblower Directive creates particularly difficult burdens for compliance professionals, as a whistleblower complaint must be investigated and reported back to the complainant within just three months.

Completing a compliance investigation in a few months is challenging in the best of circumstances. In the "big data era," when corporate data is not only incredibly voluminous but also spread across a diverse ecosystem of cloud platforms, mobile devices, computers, and traditional servers, these deadlines can seem impossible. This is even more so the case in the anti-bribery and anti-extortion context, where those large data volumes almost always include foreign language...

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