Compliance Stuff

This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP). The revised guidance reflects the government’s evolving expectations regarding corporate responsibility and compliance efforts, especially concerning artificial intelligence (AI) and emerging technologies. The key updates concern: (1) risks associated with new technologies and AI, (2) leveraging data for compliance program monitoring and enhancements, and (3) whistleblower protections. These revisions, and a brief background on the ECCP, are discussed below. Background The DOJ published the ECCP in 2017 as guidance for prosecutors for the evaluation of a company’s corporate compliance program. The ECCP identified several hallmarks of an effective corporate compliance program, which were accompanied by a set of questions for each hallmark that were meant to assist prosecutors in the review of these programs. The ECCP was created only as guidance and not as rigid standa...

  In the DOJ’s 2024 update to the Evaluation of Corporate Compliance Programs (2024 ECCP) , compliance professionals face new expectations that could reshape how we approach compliance programs. In this latest update, the DOJ strongly emphasizes data-driven insights, focusing on compliance culture, employee engagement, and organizational trust. This means that compliance programs must now focus on policies and procedures and prove that these practices are embedded into the company culture and yield measurable outcomes. The implications of these new standards extend across every aspect of compliance, from audits to employee training and risk assessments. In this post, we’ll explore the key areas of the 2024 ECCP, discussing why the DOJ’s new focus on data and culture is significant and how compliance professionals can adjust their strategies to align with these expectations. A New Focus on Data: The Backbone of Modern Compliance One of the most critical shifts in the 2024 ECCP is t...