A Side-by-Side Look at the 2024 ECCP Edits

In September 2024, the DOJ announced its first comprehensive revisions to the Evaluation of Corporate Compliance Programs (ECCP) since 2020. While a new version was published in March 2023 reflecting updates related to compliance incentives and companies’ use of messaging apps, these newest edits include “critical additions in three main areas,” Deputy Assistant Attorney General Nicole Argentieri said in her speech announcing the edits. The Anti-Corruption Report has put together this side-by-side comparison of relevant portions of the March 2023 and September 2024 ECCP versions to show exactly what has changed. See “DOJ’s 2024 Edits to the ECCP: Some History and AI Expectations” (Nov. 6, 2024).

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