Keeping up with 2023 changes to DOJ guidelines.
Additions, Deletions & Changes From 2020
2023 Evaluation of Corporate Compliance Programs
What’s in this whitepaper from Tom Fox:
In March, the DOJ released a highly anticipated 2023 update to its “Evaluation of Corporate Compliance Programs” document (ECCP), which was most recently revised in 2020. ECCP should be mandatory reading for all compliance practitioners, and podcaster and compliance expert Tom Fox gives his insights into what’s new in this year’s revision, including:
- New guidance on incentives, including proper assessment, implementation and analysis of incentive programs
- Reinforcement of consequences, including clawbacks of salary, stock options or bonus payments
- Specific guidance on use of messaging apps and the need for policies surrounding apps
Fox sums up the changes: “Obviously, the Biden Administration DOJ is stepping away from some of the initiatives of the Trump Administration DOJ. However, in other areas, this DOJ is building on some of the steps of the prior administration. It is clear that the DOJ is continuing to evolve in its thinking about what constitutes a best-practices compliance program and will continue to do so. Compliance professionals will need to study these new initiatives and implement their requirements. “
