Authors

• Jay Holtmeier

• Kimberly A. Parker

• Christopher Cestaro

• Benjamin Conery

• Caroline R. Geist-Benitez

• Molly Collett

Related Solutions

• Foreign Corrupt Practices Act and Anti-Corruption
• Investigations
• White Collar Defense and Investigations

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The U.S. Department of Justice (DOJ) recently updated the Evaluation of Corporate Compliance Programs (ECCP), which prosecutors use to assess the effectiveness of a corporation’s compliance program, in large part to address emerging risks related to artificial intelligence (AI) and similar rapidly developing technologies.¹ The ECCP, which was updated in September 2024, now requires prosecutors to assess whether a company has adequately evaluated risks and developed controls associated with emerging technologies, such as AI. As described in Principal Deputy Assistant Attorney General Nicole M. Argentieri’s remarks at the Society of Corporate Compliance and Ethics (SCCE) Compliance & Ethics Institute in September 2024, the ECCP updates address two other critical areas in addition to emerging technology and AI: whistleblower protections and access to data.

The ECCP, which was last revised in March 2023, serves as a key reference for companies seeking to understand the DOJ’s expectations. The evaluation is flexible, taking into account a company’s unique circumstances, including its size, industry, and risk profile. This guidance informs key prosecutorial decisions, including...

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