The edits to the DOJ’s Evaluation of Corporate Compliance Programs that were announced in September 2024 (2024 Edits) were broad, touching on many aspects of compliance programs. The first article of this three-part series unpacking the 2024 Edits discussed the changes related to AI, the hottest compliance topic of the day; and the second examined the many edits related to data analytics, which are still cutting edge for many companies. In this last installment, we cover changes regarding bread-and-butter elements of a compliance program that are less sexy to discuss but equally important. See “Meeting DOJ Expectations Post-Resolution Requires Realism and Accountability” (Sep. 11, 2024).