The DOJ recently announced additional changes to the Evaluation of Corporate Compliance Programs (ECCP) guidance exhibiting a refinement in its compliance expectations. The guidance was first issued in 2017 as a simple list of questions. Revisions made in April 2019 introduced additional commentary and structure to the document, and clarified that it was aimed at prosecutors, not companies. The most recent changes are less comprehensive but illustrate the DOJ’s ever-increasing compliance sophistication and willingness to understand the business realities companies face. To help show exactly what has changed, we have put together a side-by-side comparison of the relevant portions of the April 2019 and the June 2020 versions. A comparison of the April 2019 version to the original 2017 version is available here. See “Analyzing the DOJ’s New Evaluation of Corporate Compliance Programs” (May 15, 2019).