DOJ revises its “Evaluation of Corporate Compliance Programs” Guidance
The U.S. Department of Justice (hereinafter “DOJ”) has released an update to the Evaluation of Corporate Compliance Programs, 2019 guidance (hereinafter “ECCP”). The new updated 2020 Guidance to the ECCP (hereinafter “2020 Guidance”) is not FCPA specific, but it’s FCPA relevant.
The 2020 Guidance aims to help compliance professionals and corporate compliance programs in the US and beyond. The new 2020 Guidance ends the dysfunctional reliance on paper compliance programs written by lawyers for lawyers and those who implement them. The DOJ now assumes that both the business and compliance communities have learned that compliance is a business process. And as a process, it could be measured, managed and, most importantly, improved.
Find the DOJ’s blog and the new 2020 Guidance here: https://www.justice.gov/
Find the most meaningful changes to the ECCP here: http://fcpaprofessor.com/doj-