DOJ Prosecutors Revise Guidance On Compliance Programs

The Criminal Division of the Department of Justice has issued a revised version of a guidance outlining the factors it will consider when making enforcement decisions in matters of corporate malfeasance – whether and how to charge, recommended sentences, and reporting or monitoring requirements. The new version of the Evaluation of Corporate Compliance Programs (ECCP) makes what appear to be minor changes from earlier versions, but companies would do well to note the differences, explains this post from the BoardAndFraud blog: “In essence, having a compliance program is not enough; it must be continuously evaluated and revised accordingly … using business intelligence and lessons learned…”