Which is more likely: a company coming under DOJ investigation or a commercial building being destroyed by fire? Answer: DOJ investigation.
Don’t believe me? Destruction from fire is less frequent due to modern fire safety measures and rapid response times. According to the National Fire Protection Association, there were about 130,000 non-residential building fires in the US in 2022, a low probability per building, given there are almost 6 million commercial buildings in the US. On the contrary, the range of issues that trigger DOJ investigations is vast, and the proliferation of government whistleblower programs has increased the likelihood of detection.
Yet, despite the statistical differences, companies are more willing to install fire extinguishers and buy insurance than invest in compliance programs that satisfy DOJ “Evaluation of Corporate Compliance Program” guidance. Just as building owners buy fire insurance and keep fire extinguishers on hand — not expecting a fire but ready for the worst — companies should invest in ECCP-compliant programs because it makes good business sense. Both investments are made with the hope that they will never be needed and the understanding that the benefits of prevention and timely detection far outweigh the potential expense and disruption that arise from unanticipated events. Following the updated ECCP guidance means taking concrete steps.
Read more in Corporate Compliance Insights about what four steps organizations should take to prepare for DOJ scrutiny in 2025 and beyond.
If you have any questions or would like to find out more about this topic please reach out to Jonny Frank.
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