Welcome back to the podcast, Brib, Swindle, or Steel.

I'm Alexandra Ragi, and today we'll hear from Chuck DeRoss on the compliance risks associated with messaging apps.

Chuck led the FCPA unit at the DOJ before joining Morrison and Forrester where he co-leads

the FCPA and Global Anti-Corruption Practice. Chuck spoke about this compliance challenge

at the Trace Forum in Annapolis and included some suggestions while acknowledging that

it's a difficult issue. Here's Chuck.

I'm here today to deal with the very simple issue of messaging apps and sort of DOJ's evolving guidance.

So let me first talk a little bit about the history, just to give people a sense.

I think most people in this audience probably have some idea about this.

But, well, let me step back, and I'll say, why does DOJ care?

DOJ care, for the same reason that I suspect, most of the people in this room realized that

email is not actually where most people talk about bad stuff anymore.

That's just a fact.

You're conducted internal investigations and looked for it.

It used to be that emails were where people talked about things. They would sort of forget that this is all part of the system. And, you know, when I was at DOJ, running the FCPA unit, we would see things like delete after reading. And you're like, yeah, that doesn't happen, actually. It doesn't. It's on a server. Or we would see things like, thank God for the FCPA, ha ha, ha,

you know, and you're like, we'd like tape that to the door.

So people would send some pretty crazy stuff, you know, email.

But now people don't kind of migrated to text messages.

People will use, sometimes they'll use chat functions.

For example, whether it be teams or other kinds of instant messaging apps.

But really there's this advent of messaging applications, and there are a lot of them that are out there.

And they have become the communications channel for people who want to speak sort of offline.

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