ECCP Edits Provide More Nuance on Training, M&A and Third-Party Management

At a high level, the edits to the DOJ’s Evaluation of Corporate Compliance Programs (ECCP) quietly released in June 2020 are focused on encouraging companies to find ways to constantly improve their compliance programs. However, the edits also provided some further refinements in specific areas of compliance, namely training, mergers and acquisitions and managing third parties. In this second article taking a close look at the 2020 edits, we analyze these specific suggestions with former DOJ attorneys. The first article looked at how the new edits encourage companies to make compliance a positive feedback loop based on “lessons learned.” For a side-by-side comparison of the April 2019 and June 2020 versions of the ECCP, click here.

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