DOJ’s 2024 Edits to the ECCP: Some History and AI Expectations

The DOJ has updated its Evaluation of Corporate Compliance Programs document (ECCP) – a year after it hired former AB InBev CCO Matt Galvin to take the lead on evaluating compliance programs. Galvin, an evangelist for the use of data analytics and artificial intelligence (AI) to improve compliance programs, clearly influenced the edits, which heavily focus on the use of new technologies and data. In this article, we examine the history of edits to the ECCP and the new changes related to AI. A future article will explore other changes in the ECCP, such as an increased focus on protecting whistleblowers from retaliation, how compliance is viewed within an organization, how companies should be incorporating lessons learned into their programs and the DOJ’s continued focus on data analytics. The third article will discuss additional changes that touch on anti-retaliation, compliance resources and how companies should incorporate lessons learned into their compliance programs. See “Revisiting Compliance Programs in Light of the DOJ’s Updated ECCP” (Sep. 30, 2020).

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