A Close Look at the New ECCP’s Commentary on Compliance

The DOJ’s original Evaluation of Corporate Compliance Programs (ECCP) was, for the most part, a list of questions prosecutors might ask about a company’s compliance program when negotiating a resolution. The recently released updated version of the guidance reorganizes and reframes those questions with significantly more commentary. In a previous article analyzing the ECCP, we looked at the new structure of the document and the fact that it is now aimed expressly at prosecutors. In this article, we examine the new narrative commentary the DOJ provides as well as several specific areas of focus in the new guidance. For a side-by-side comparison of how the questions prosecutors should ask have changed, click here. See “Analyzing the DOJ’s New Evaluation of Corporate Compliance Programs” (May 15, 2019).

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