Heading into 2025, the DOJ is making its priorities increasingly well-known. As DOJ scrutiny increases, companies that prioritize compliance programs and controls that meet “Evaluation of Corporate Compliance Program” (ECCP) standards will be better equipped to anticipate and manage compliance risks and scenarios, detect and address compliance violations and weather any unexpected regulatory challenges. To meet the updated ECCP standards, organizations should:
- Conduct AI-facilitated ECCP gap assessments: Use generative AI to analyze compliance policies, processes, and controls against ECCP criteria, streamlining assessments and enabling actionable insights.
- Address recent ECCP updates: Including electronic communications and data & technology updates which establish policies to collect and preserve business data and identify and manage risks from AI and emerging technologies, respectively.
- Close gaps: Develop documented, comprehensive corrective action plans with clear governance, timelines, and milestones to address identified deficiencies.
- Test compliance programs and controls: Independently test to validate a compliance program’s effectiveness and ensure controls mitigate risks within appetite levels.
Read more in Corporate Compliance Insights about how 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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