Time to Rethink Corporate Compliance amid DOJ’s New Guidelines

The U.S. Department of Justice (DOJ) announced significant changes to its Evaluation of Corporate Compliance Programs (ECCP) on March 2, 2023, at the American Bar Association’s National Institute on White Collar Crime. By investigating deeper into companies’ compliance programs, DOJ now provides new stricter guidelines and emphasizes its vigilance and the level of commitment expected from companies. The latest announcement illustrates DOJ’s continued emphasis on company policies regarding compliance incentives and disincentives in executive compensation and the preservation of company communications made via personal devices and instant messaging applications.